ML20202D455
| ML20202D455 | |
| Person / Time | |
|---|---|
| Issue date: | 06/18/1974 |
| From: | Nelson J NRC |
| To: | |
| References | |
| SECY-A-74-128, SECY-A-74-128-R, NUDOCS 9902010401 | |
| Download: ML20202D455 (14) | |
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l-SECY-A. 7 4 -12 8 l- (QF June 18, 1974
- s, ADJUDICATORY ITEM l
SUMMARY
SHEET
Subject:
As Low.As Practicable Proceeding.
Purpose:
Proposed questions for submission to parties.
Discussion:
When this case was last considered, the Comission requested preparation of three questions which could be propounded to the parties. The draft questions were to be submitted to the Comission, which would decide whether to ask them.
The three Oak Ridge consultants accordingly suggest the following questions:
1.
"During the Oral Argument it became clear that little or no consideration had been given.to the potential impact of Proposed Appendix I on the concept of nuclear parks.
"The Comission would appreciate receiving your analysis of the potential impact of Proposed Appendix I on Nuclear Power Parks which might 3
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g contain as many as 20 Light-Water Reactors.
If e-a tra -
W your analysis indicates that Nuclear Parks would not W
M be feasible under proposed Appendix I, would you suggest provisions for overcoming this objection 2
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E which the Comission might consider for inclusion
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in the Proposed Rule."
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2.
"The Comission is interested in how well actual C
field measurements and experimental data support
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the assumed values of the parameters which charac-terize the cow-milk-thyroid dose pathway. With respect to each parameter used in calculating doses 7
by this pathway, they would particularly like to sagpA witt Se@d know the range of values which have been derived from field measurement or experiment, the best value 4y g
to use for each parameter in establishing design WWbe&%
objectives, and the reasons for selection of each value."
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2 3.
"A firm dollar figure for worth of population dose reduction was assumed and used by only one party in the ALAP hearing; the Consolidated Utilities Group used $1000 as the value of 1 man-rem reduction in dose. Recognizing that additional human, aesthetic, and environmental factors must be given weight, the Comission nonetheless would like to have the benefit of the participants' comments on the reasonableness of the $1000 per man-rem value. The parties may also j
wish to suggest another figure with supporting justi-fication for consideration."
Dr. Bryan is reviewing the submissions made on June 17 (pursuant to the Commission's order at oral argument) to determine whether they have any bearing on the ques-tions.
I will comunicate his advice to the Comission.
Scheduling:
This matter is on the adjudicatory session scheduled for June 21, 1974.
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!.f[CtA Jerome Nelson vSolicitor DISTRIBUTION NO. OF COPIES Secretary 9
Chairman Ray 3
Commissioner Larson.
2 Commissioner Doub 2
Commissioner Kriegsman 2
Commissioner Anders 2
Solicitor 4
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I.
SECY-A-74-128 - As Low As Practicable Proceeding three ALAP consultants for Commission review and possib to all the participants to clarify the Record in the As Low As Practicable Proceeding.
- A.
The Commission noted thate 1.
the Solicitor recommended a decision on submitting the questions to the A. LAP pt.rticipants be deferred pending a meeting.with the AEC's consultants in view of the additional submissions (received from the staff and the General Electric Company)which the consultants wish to review, as well as Commissioner Anders' request for additional time to consider the Record of the Proceeding; 2.
in response to a question from Commissioner Doub, the Solicitor indicated the earliest date for a meeting with the consultants would be June 28; that if questions are submitted to the participants, they should be allowed ten days to submit their responses; and that under these conditions; final Commission consideration of the ALAP matter will not be possible before mid-July, which will delay.s final decision until mid-August; he added this process could be expedited if the three Oak Ridge consultants can be released from their other duties to concentrate their attention on this Proceeding; 3..
the Chairman ' agreed it would be desirable for the consultants to devote their full time to this matter
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provided such an action would not seriously affect other on-going work to which they have been assigned; 4.
in response to Commissioner Kriegsman's question concerning the advantages, from a legal standpoint, of requesting additional information from the participants, the Solicitor indicated the purpose of requesting additional information would be to clarify the Record to assure an adequate basis for rendering a policy decision and that such a~ course of action would not produce any legal advantages or disadvantages.
B.
The Commission deferred SECY-A-74-128 pending a meeting with the ALAP consultants to be scheduled for Friday, June 28.
(Solicitor /SECY)
C.
The Commission requested the Acting Secretary to explore 6~
,l' the possibility of releasing the consultants from their
_other' duties to-concentrate on the As Low As Practicable 2'
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Proceeding.
(SECY)
Adj {Sess 42 '
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III.
As Low As Practicable Proceeding-i A.
The Commission noted that:
I 1.
there are two courses of' action available in the after-math of.the oral arguments:
a.
the Commission can. direct that the hearings be reopened for the purpose of obtaining additional evidence, or b'.
the Commission can accept the record-andiprovide staff the guidance necessary to draft its decision paper; 2.- while the staff' felt the record was ' excellent and' ample for a decision, Dr. Ray found the record wanting in certain respects; i
3.
returning the record for additional evidence would i
have little practical effect on the staff, and they would continue to operate under present procedures; 4.
it would-be possible to give interim guidance to the staff iflthe record is returned; 5.
Commissioner Anders felt that establishing numerical criteria violated the ccncept of "as-low-as-practicable;"
furthermore, sincetthe utilities relied upon cost benefit analysis and the staff did not, it was k g. # gj difficult to find'a common ground upon which to make em p3
$ggg gy-a comparison.of the two positions without resorting rs -
to a man rem / dollar relationship; finally, the i
WE kp record' lacked both comparative risk assessments and i
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'M an evaluation useful to the consideration of the k
r-4 nuclear park concept; g
at ' 6.
Dr. Ray added that with such data missing, it was 6
possible that-the_ Commission might take actions which j
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wouldr effectively foreclose consideration of multiple-reactors at a site; at this point Dr. Ray excused herself from the meeting; 7.
- in response'to a question by Commissioner Larson, the Solicitor suggested asking for written papers as a way to clarify'the record without repeating the entire' process; 8.
Commissioner Kriegsman considered these problems in the realm of implementation and felt that'they could not be_ satisfied by'any additional evidence;
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seeking additional facts, but were only asking staff to consider issues they had not considered previously;
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Commissioner Kriegsman asked whether the Commission i
could seek written evidence as well as offer guidance to the staff so that they could proceed with their report and not delay the process; staff said this was possible; 10.
staff sought guidance on four issues:
a.
whether to accept consdrvative calculations or realistic calculations, b.
site based criteria versus reactor based criteria, c.
what role ALAP will play for LWRs, and d.
how backfitting will be handled in situations where a reactor was built in accordance with the regulations, but the regulations changed; 11.
the following should guide staff in the four issues noted above:
a.
realistic and appropriately conservative calcu-lations should be defined and used, b.
the report should be worded so as not to preclude considerations of multiple reactors per site, c.
ALAP should remain as a staff tool, and d.
backfitting would be considered on a case-by-case basis.
B.
The Commission approved circulating a draft letter as a Consent Calendar item, requesting written evidence from each of the parties participating in the proceedings.
(Solicitor)
C.
In the meantime, the Commission directed the staff to begin work on their report.
(Solic' tor) l c.
te /'
aul C. Ben r
Secretat y of the Commission (12:00 p.m.)
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SECY-A-74-128 - As Low As Practicable Proceeding A.
The Commission noted that:
1.
there were two matters requiring consideration:
a.
whether to ask of the parties involved in the hearings questions prepared by the consultants at Commission request, for the purpose of augmenting the record, and b.
to evaluate the assumptions and conservatisms in the staff's proposed rule; 2.
the technical consultants from Oak Ridge presented an actual iodine pathway to illustrate the calculations used by staff in determining the amount of iodine released at each stage, and the factors which would tend to mitigate the amounts of iodine released; staff emphasized that the pathway presented was only one of many, but the calculational assumptions were derived in the same manner in every case; 3.
in this instance, the radioactive iodine in the fuel was passed on to the reactor coolant, where the first evidences of iodine's presence were established; from the coolant the iodine moved into the steam and out through various minor leaks in the turbine into the atmosphere; the turbine leaks were very small but in the aggregate accounted for the iodine released to the atmosphere in this model; in other models the iodine could escape through such things
'as cooling chimneys; from the atmosphere the iodine was deposited onto pastures, eaten by dairy herds and passed into the milk; once ingested by the receptor, iodine often builds up in the thyroid; 4.
measurements of these amounts are always difficult p h,3993 to obtain, particularly when confused by weapons 1
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testing in the atmosphere; among the factors an applicant is permited to use in defending his
$gAk-b2L as y '{'gpfjp reactor's performance is the decay rate of iodine 131 Wp Q
and the effects of pooling the milk produced; 2
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the applicant's data and calculations must change if a
land usage around the reactor changes; however, under 64 9-the "as low as practicable" guidelines, if for some
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E extraordinary reason the best available technology
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i still produces unacceptable results, the permissable S
f dose values are increased to accommodate the atypical situation; i
6.
Commissioner Anders disliked the concept of "as low Adj Sess 75-1 as practicable", particularly the tendency under July 2, 1974 these guidelines to apply the numbers independent of either biological or technical factors; 1
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7.
Dr. Bibb's immediate purpose was not to defend the concept, but to use the record as the basis for a draft Commission decision; the draft will in turn become the basis for a discussion on the principles involved; in this regard, the consultants considered the evidence in the record ample for a draft report and that little could be gained by sending out the questions suggested in SECY-A-74-128; 8.
Commissioner Anders suggested both writing drafts and sending the parties the questions included in the paper; 9.
with respect to the questions suggested in the paper, Commissioner Anders felt that question 3 missed his original point, that the particular value of a man-rem is not as important an issue as a discussion of the value of the technique of using man-rems; also, the nuclear parks issue addressed by question 1 was intended to express the opinion that any numerical criteria for mrems placed on a reactor would evolve into a concrete requirement for sites, effectively precluding nuclear parks; Commissioner Anders wanted to see some criteria developed for site requirements, working back from the individual 500 mrems concept now operating since the total population dose approach was not valid here.
10.
staff felt that the record was still sufficient as it stood to permit discussions in the draft from either a per reactor or per site viewpoint; however, staff admitted that the record was not sufficient to handle nuclear parks in numbers greater than 6; (The meeting adjourned at 4:45 p.m. July 2, and was continued July 3 at 8:30 a.m.)
11.
Dr. Ray requested a summary of yesterday's discussion prior to proceeding with business; such a summary l
was provided by the staff; l
12.
after the drafts are provided by staff, the issue of the questions to be submitted by the Commission to the parties involved will be raised again; and 13.
these drafts will be ready for Commission consideration by August 1, 1974,'after input from legal staff.
B.
The Commission decided to postpone consideration of the questions contained in SECY-A-74-128 until it has an opportunity to review the consultants' draft decision.
(Solicitor)
C.
The Commission directed the consultants to continue writing their draft decision, to be presented to the Adj Sess 75,1 Commission sometime around August 1 (solicitori
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I VII.
SECY A-75 As Low as Practicable Proceedings, RM-50-2 The Commission discussed the prelim ~inary draft conclusions of the Commission's.ALAP consultants on numerical guides for design objectives and technical specification require-ments for limiting. conditions for operation of light-water-cooled nuclear power reactors to keep radioactivity in effluents as low as practicable.
A.
The Commission noted that:
1.
Dr. Bibb explained the ALAP consultants had requested and had received Commission permission to draft their own version of a proposed rule on numerical guidelines for As Low As Practicable (Appendix I to 10 CFR Part 50); in the consultants' view their draft pre-liminary conclusions are supported by the P.ecord and take into account the views of c.11 the participants in the ALAP Proceedings; 2.
in response to Commissioner Kriegsman's question concerning the necessity of another hearing in the event the Commission adopts a rule differing from the proposed Appendix I developed by the Regulatory staff, Mr. Silverstrom indicated the purpose of the ALAP-Hearing and Oral Argument sessions was to elicit the information necessary to promulgate an effective rule; as a result, any numerical guidelines adopted by the Commission will be published in final form; 3.
summarizing the conclusions of the consultants, Dr.
Bryan observed that:
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7-November 11, 1974 Adj. Sess. 7 5-9 September 30, 1974 as design objectives for liquid effluents, based a.
on individual dosages and the number of reactors on-site, the consultants recommend the following:
individual exposures in millirems from all reactors on site or nearby
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per_ reactor /
site per per year year
. total body 5
10 skin 30 60 any_ organ 15 30 these figures correspond most closely with those recommended by the General Electric Company and do not include quantity and concentration limits, as recommended by the Regulatory staff, r_or limits for specific organs, as recommended by Consolidated Utilities; the limits established are sufficient to accommodate. four reactors on a site, assuming utilization of treatment facilities currently available, b.
as design objectives for radioactive materials released to the atmosphere, the consultants recommend the following:
1.
individual exposure in millirems from all reactors on site or nearby per reactor /
site per per year year total body 5
5 skin 30 30 2.
airdoses re occupiable off-site location in millirads~~
Alpha 10 30 Beta 20 60 OFFHCHAL DSE ONLY
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September 30,-1974 under these guidelines, the Regulatory staff will I
have the option of imposing individual dosage design objectives in lieu of airdose limits in the event greater protection of the individual is deemed necessary, and i
as design objectives for radiciodine and particulate c.
matter discharged to the atmosphere the consultants recommend the following:
individual exposure in millirems 4
from all reactors on-site or nearby per reactor /
site per per year year 15 45 1
any organ i
(thyroid) these figures do not include quantity and concen-tration limits as recommended by the Regulatory staff; Commissioner Anders, referring to the design objectives 4.
for radioactive materials released to the atmosphere, questioned the variance between per reactor and all reactor dose limits es.tablished for the Alpha and Beta airdoses, while for individual exposures, the limits established for one or more reactors are identical; Dr.
Bryan explained that the airdose limits refer to annual exposures permitted at a given fixed location at or' beyond the reactor site boundary; while intended primarily to provide design objective flexibility for consideration of such factors as site-related meteorology and the distance of the reactor from the site' boundary,the air-dose limitations also assume that individuals may live just outside the site boundary, but only under the hypothesis that individual occupancy at any given location is constant (100% of the time); this is in contrast to the individual dose limits which take into account individual mobility, shielding and other factors; the specific limits established for both individuals and airdoses are both practical and supported in the Record of the ALAP Proceeding; Commission Anders indi-cated that a more detailed explanation is necessary to
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Adj. Sess. 75-9 November 11, 1974 September 30, 1974 5.
in response to Commissioner Kriegsman's question con-cerning the impact of the consultants' conclusions on the industry and the general public, Dr. Bibb indi-cated the industry response should be favorable since the recommended dose limitations are slightly more
. liberal than those proposed by the Regulatory staff and quantity / concentration limits have been eliminated; i
i at the same time the recommended limitations are sufficiently close to those proposed by the staff that the consultants anticipate staff acceptance as well; Mr. Silverstrom pointed out that the general public i
may perceive the consultants' recommendations as concessions to the industry position on this matter in view of:
l the emphasis placed on realistic, rather than a.
conservative assumptions, b.
the similarity between the dose limits in the consultants' recommendations and those of such industry participants as the General Electric
- Company, the emphasis on per reactor emissions as opposed c.
to overall site emissions, d.
the exclusion of nuclear parks from the scope of the decision, and despite the specific dose limits established in e.
the report, provision is made in special cases for complying with the As Low As Practicable require-ment on a case-by-case basis; in response to Commissioner Kriegsman's question l
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concerning implementation of the criteria developed F
Mr. Silverstrom stated the by the consultants, consultants' recommendations were submitted in draft form to elicit Commission comments or guidance prior to finalization; 7.
Commissioner Anders, referring to Part B, pp. 36-41 of the draft report, expressed reservations concerning i
the rationale for correlating i[n[dividual and population dose limits; explaining that hd ose 30t accept the concept that "As Low as PracticaDien is equivalent to "As Low as Achievable", Commissioner Anders pointed out n
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OFFHCHAL USE ONLY Adj. Sess. 75-9 November 11, 1974 September 30, 1974 that final Commission action on this matter will set a major precedent either on the dosage limits estab-lished or the process by which these limits are derived, and that the consultants' conclusions appear,
to perpetuate the rationale that if individuals living near the s'ite are well protected, dosage levels to the population will be low -- such a correlation of population and individual dose limits yields extremely low exposures for individuals which are unrealistic and unjustifiab1'e from a statistical basis; as an alternative, Commissioner Anders suggested that while the benefits of nuclear power should be commensurate with the risk to the general population, calculations of the impact of site-related emissions should be based on the potential somatic effects on the individual expressed in terms other than man rems; this approach would effectively separate the concepts of population and individual dose rates and promote greater reality and credibility in the Commission's final rule; 8.
Mr. Silverstrom observed that Commissioner Anders' approach could yield relatively high individual dosages expressed in rads and might pose a public relations problem by the necessity for the Commission to defend such high numbers as insignificant in terms of public health and safety; Dr. Bibb indicated an additional problem is the necessity to define what level of exposure (expressed in rads) is acceptable; 9.
the Chairman commented that while it would be diffi-cult now for the Commission to radically revise its philosophy on exposure limits, particularly in view of the necessity to adopt a reasonable position supportabic by the Record of the ALAP Proceeding as well as past practice, it would be desirable to include in the final rule some discussion of the problems associated with the criteria as adopted, and additional analysis to clarify that the final rule will remain a working rule which is subject to change as the need arises; and 10.
Commissioner Anders reiterated that he was not proposing any " radical" changes to dose levels, but that he was proposing derivational consistency in how dose limits are. established; he stressed that the ALAP consultants should not use limits justified on the basis of long-term genetic effects on the population as a whole for individual limits where there is no statistical rationale for such genetic effects.
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AFFHCEAL USE ONLV t November 11, 1974 Adj. Sess. 7 5-9 September 30,.1974 i
B.
The Commission requested revisions in Part B of the ALAP consultants' draft conclusions a'nd greater emphasis on the uncertainties associated with the proposed criteria.
~(Drs.Bibb G Bryan / Solicitor)
Gordon M. Grant Acting Secretary of the Commission '
-(Adj ourneck :
3:30 p.m.)
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. Memorandum for the Record SECY-A-75-20A - Ruling on As Low As Practicable
- A.
Dr. Ray stated that after studying this problem, she concluded that there were still. innumerable questions unanswered.
It may'not.be possible to reach definitive, or even defensible answers to as-low-as-practicalbe, but the; effort must be made.
The complexity and scope of' the problem are such that the new NRC, the agency which will have to operate with the guidelines, should not be committed to a decision hastily reached by the AEC.
She recommended deferring the issue to the NRC, and suggesting to the NRC that this matter receive its highest priority.
'B..
Commissioner Anders shared the Chairman's sentiments.
The new agency and its Commissioners should not be prejud. iced by prior decisions.
The issue deserves a fresh looksao it makes sense to pass it on to the NRC.
C.
Commissioner Kriegsman asked if it were clear that the task could not be completed in three or four days.
The staff responded that three or four days would he clearly insufficient to complete the-project.
Commissioner Kriegsman seconded the recommendation of the Chairman.
D..
Mr. Silverstrom, Solicitor's Office, stated that the recommendation of the Chairman reflected the feelings of the staff working on the paper.
He felt that some Commission decision at this point might indeed L
prejudice the NRC.
'E..
The Commission commendsd the staff working on the problem for an extensive and honest effort and determined under all the circumstances to defer the as-low-as-practicable problem to the NRC.
(Solicitor) g 1
'ADJ Pol. Sess. 75-17 12/31/74 p
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