ML20214S047
| ML20214S047 | |
| Person / Time | |
|---|---|
| Issue date: | 06/01/1987 |
| From: | Kammerer C NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| To: | Dewling R NEW JERSEY, STATE OF |
| References | |
| NUDOCS 8706090107 | |
| Download: ML20214S047 (2) | |
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NUCLEAR REGULATORY COMMisslON j
WASHINGTON, D. ( 20555 JUN 01 587 Richard T. Dewling, Comissioner Nm Jersey Department of Environmental, Protection CN-402 Trenton, New Jersey 08625
Dear Comissioner Dewling:
This is to acknowledge receipt of your letter addressed to Wayne Kerr dated May 6, in which you forwarded coments on "The Advanced Light Water Reactor Utility Requirements Document, Executive Sumary."
I have referred your letter to Herbert N. Berkow, Director, Standardization and Non-power Reactor Project Directorate, Office of Nuclear Reactor Regulation, who will address your coments and provide you with supporting documents as they become available.
I would like to take this opportunity to thank you for your views on this NRC continues to be interested in the States' perspective and we will sumary.
continue to solicit your opinion concerning matters in the regulatory arena.
Sincerely, 4p / $(
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arlton Kamerer, Director State, Local and Indian Tribe 'rograms r
Office of Governmental and Public Affairs
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, g,, l^f DEPARTMENT OF ENVIRONMENTAL PROTECTION OFFICE OF THE COMMISSIONER CN 402, Trenton, NJ 08625 609-292 2885 RICH ARD T DEWLING, Ph.D., P.E.
MICH AEL F. C ATANI A CoMMISSloN E R DEPUTY CoMMISSloNER May 6, 1987 Mr. Wayne Kerr AR-5303 USNRC Washington, D.C.
20555
Dear Mr. Kerr:
This is in response to a letter from Mr. Harold R. Denton requesting my views on the nuclear industry's report "The Advanced Light Water Reactor Utility Requirements Document, Executive Summary."
Mr.
Denton requested that I direct my comments to you.
My comments are based in part on my review of the Executive Summary. Without the benefit of Parts II and III of the Requirements Document, which contain plant design requirements for Advanced Light Water Reactors (ALWR) and supporting technical evaluations, 7
respectively, it is not possible for me and my staff to comment substantively on the technical reliability of this industry initiative.
I therefore offer these comments primarily from within the context of our experience with existing nuclear plants operating in New Jersey and elsewhere.
The document gives us the general impression that the ALWR program is an initiative driven much more by the need to increase the economic viability of the nuclear option than a need to substantially increase pir.nt safety.
If the ALWR Requirements Document reflects the utility industry's efforts to revive and assure a viable nuclear power option in the United States, I think those efforts need to provide convincing evidence that ALWRs will truly be a major step forward in improving nuclear power plant safety.
For example, an inherently safe light water reactor (LWR) design would remove much of the doubt presently in the minds of the public and government officials about nuclear plant safety.
This could also set the stage for location of nuclear plants in or near densely populated areas from which increased electric demand will be generated. This approach provides both safety and economic benefits that are clearly demonstrable.
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Mr. Wayne Kerr May 6, 1987 I believe that the information in the Executive Summary provides the impression that the ALWRs are nothing more than modified versions of the present LWRs operating in the U.S.
The ALWR report essentially documents an industry initiative. The initiative is based on the idea that by providing some additional " fixes" to generic problems identified with the present LWRs we will provide an economic solution to assure a viable nuclear option for future electric power needs.
From our review of the Executive Summary we identified a number of areas on which we could comment (e.g., elimination of regulatory uncertainty, operating performance, plant life, radwaste, design margin and safety). However, I will focus on one issue that is, perhaps, most relevant to State officials at this time and that ties design margin and safety together as a point of discussion.
It may also provide a specific example of how the Executive Summary may not provide the impression you wish to convey and may, as a matter of fact, provoke debate. Emergency planning for nuclear power plant accidents is based, to some extent, on the idea that protective action recommendations provide an additional safety margin for the publ.'c in the highly unlikely event of a severe nuclear plant accidtoc. Hevever, at the present time there is also a major debate taking piece between Federal and State governments about the role states will play in the future for emergency planning for nuclear power plant accidents. In addition, the nuclear industry has been aggressively pursuing an init!ative to convince public officials and the U.S. Nuclear Regulatory Commission (NRC) that emergency planning zones can be significantly reduced around most nuclear plants operating today.
Within that context, the Executive Summary, section 2.2 " Safety" states that "The ALWR will be designed and constructed such that it is substantially safer than existing plants.
In particular, the plant is designed so that for any severe accident which is likely to occur more frequently that once per mfIlion years, the dose to someone residing one-half mile from the reactor would be less than 25 rem whole body, a level at which no observable effects will occur."
This is not a reassuring statistic from a State perspective because it is not a convincing argument that ALWRs are significantly safer than nuclear plants operating today. Federal guidance to those of us responsible for public safety at the State level dictates the use of protective actions for the public at doses lower than 25 rem for the present generation of LWRs.
It would appear that the best we can expect from the ALWRs is possibly, a slight reduction in the emergency planning zone.
Even that is questionable since there has been and continues to be significant population growth in close proximity to nuclear plants presently located in or near major population centers, including New Jersey. I would assume that to meet economic criteria for future needs nuclear plants will continue to be sited in reasonable proximity to large populations.
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- a Mr. Wayne Kerr May 6, 1987 In addition, the industry suggests that a dose of less than 25 rem is a reasonable criterion for judging increased safety because there are "no observable health effects." Our experience with discussing y
carcinogenesis in New Jersey would strongly suggest that this design I
criterion is much too one-dimensional to support the idea that ALWRs are
.l a major step forward in nuclear plant safety. Again, it certainly s
leaves a lot of room for debate. Ignoring the potential long term effects of population exposures in the range of 5 to 25 rem leaves considerably more room for doubt about whether ALWRs reduce public risk significantly compared to today's LWRs.
I appreciate the opportunity to provide comments to the NRC on this industry initiative and I look forward to receiving the additional supporting documents as they become available.
Sincerely, 3
xtt.)
Richard T. Dewling c:
Assistant Commissioner Defeso Director Berkowitz v
Assistant Director Nicholls
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