ML20217D775
| ML20217D775 | |
| Person / Time | |
|---|---|
| Issue date: | 08/10/1999 |
| From: | Dicus G, The Chairman NRC COMMISSION (OCM) |
| To: | J. J. Barton HOUSE OF REP. |
| References | |
| CCS, NUDOCS 9910180138 | |
| Download: ML20217D775 (85) | |
Text
OC/9/A UNITED STATES NUCLEAR REGULATORY COMMISSION G
WASHINGTON, D. C. 20066
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August 10,1999 -
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'cwunuAm The Honorable Joe Barton, Chairman Subcommittee on Energy and Power Committee on Commerce
-United States House of Representatives
' Washington, D.C. 20515
Dear Mr. Chairman:
Thank you for the opportunity to appear before your Subcommittee on July 21,1999, to discuss the important issues regarding reauthorization of the Nuclear Regulatory Commission. We appreciate the opportunity to provide input on H.R. 2531.
I am enclosing the NRC responses to post-hearing questions. Please contact me if I can be of further assistance.
Sincerely,
/t d 8J t
reta Joy Dicus
Enclosure:
As Stated cc: Representative Ralph M. Hall
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9910180138 990810
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PDR COMMS NRCC CORRESPONDENCE PDR
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u QUESTION 1.
A recent NRC press release states that the " security program will be incorporated into the NRC's baseline inspection program when it is fully c
implemented early nextyear." My understanding was that the program is suspended as part of the baseline inspections until a new rule-making is completed.
(A)is that correct?
ANSWER.
No, a security inspection program similar to the NRC's long standing regional inspection program continues to be an integral part of the baseline inspection program.
The ongoing OSRE inspections'will continue to require licensees to demonstrate the response capability of their security organizations, including force-on-force exercises, as planned. At present, the last OSRE is scheduled for May 2000. The staff, with stakeholder involvement, is exploring options to continue the evaluation of licensee demonstration of contingency response capabilities during the period between completion of the OSREs and issuance'of the final rule, whenever that occurs, and plans to forward its recommendation on these options to the Commission in September 1999.' This transition plan will ensure force-on-force exercises continue following May 2000 though the completion of the rulemaking.
in a letter dated August 31,1999, the Nuclear Energy Institute (NEI) commented on the new rulemaking you mentioned. in its letter, NEl informed the Commission that the industry is preparing a guidance document for a pilot program that could be implemented in mid-2000
l-QUESTION 1.(A). (Cont.)
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when acceptable to both the NRC staff and the industry. Key elements of the NEl pilot program guidance include identifying target sets based on a goal of prevent.ing a radiological release
' that exceeded 10 CFR Part 100 criteria, force-en4orce drills and exercises, tools for evaluating the eifectiveness of drills and exercises, and a process for correcting deficiencies. The
- Commission intends to consider the viability of the industry proposal within the framework of the staff's September 1999 recommendation to the Commission.
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3 QUESTION 1.
-A recent NRC press release states that the " security program will be L
incorporated into the NRC's baseline inspection program when it is fully implemented early next year." My understanding was that the program is l
suspended as part of the baseline inspections until a new rule-making is
. completed.' '
(B)
.When do you expect the rule to be finished?
ANSWER.
The NRC staff has proposed -- and the Commission has approved -- an aggressive rulemaking schedule to amend Part 73 to require periodic contingency be an integral part of the baseline inspection program. The rulemaking is currently expected to follow this schedule:
September 17,1999
- rulemaking plan to Commission March 31,2000
- proposed rulemaking to Commission May 2000
- 60 day public comment period December 1,2000
- final rulemaking to Commission May 1,2001
. - final rule published i
However, at a public meeting on August 11,1999, there was significant stakeholder comment on the need for a more comprehensive Part 73 rulemaking. If the Commission agrees to i
broaden the rulemaking, this aggressive schedule could be delayed. Furthermore, as
. mentioned in the response to the previous question,' the industry has proposed a goal of
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I developing, over a two-year period, a broader rule change and supporting industry Wng guidance.
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QUESTION 1.
A recent NRC press release states that the " security program will be incorporated into the NRC's baseline inspection program when it is fully implemented early next year." My understanding was that the program is suspended as part of the baseline inspections until a new rule-making is completed.
(C)
How long does rulemaking usually take?
ANSWER.
In recent years, many rulemakings have taken approximately 24 months from approval of a rulemaking plan by the Commission. However, many high priority rules have been adopted on a faster schedule. Our August 27,1999 letter to Congressman Markey and the response to 1(B) discuss this proposed rulemaking schedule.
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r-QUESTION 2.
(A)
Will you commit to including force on-force drills in the baseline inspections when they start, whether or not the rule-making is L
finished?
ANSWER.
SpecHic commitments at this time would be premature since the Commission has not reviewed the staff's proposal. The staff will provide options for Commission review in September 1999.
NRC inspection of license-conducted force-on force exercises is currently under discussion between NRC and its stakeholders, including the recent industry proposal to prepare a guidance document for a pilot program that includes force-on-force drills which, if found acceptable to the NRC and the industry, could be implemented in mid-2000. Whether force-on-force drills are required under the auspices of the baseline inspection program or as a continuation of the current approach to OSRE is among the options being evaluated by the staff j
i at this time.
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l QUESTION 2.
(B)
Will you commit to ensuring there is not a gap between the end of the OSRE drills next spring and the inclusion of drills in the baseline inspection either by continuing the OSRE program or beginning the baseline inspection drills?
I ANSWER.
Specific commitments at this time would be premature since the Commission has not reviewed 4
the stafra proposal. The staff is providing options for Commission review by September 1999
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as discussed in our responses to 1 (A) and 2 (A).
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QUESTION 2.
(C).
Does the NRC need new legislation in order to enable you to 3
requ!re licensees to conduct these drills right now?
ANSWER No, the NRC does not need new legislation in this area. _ Under the Atomic Enerin Act of 1954,
- as amended (AEA), NRC has ample authority to regulate the operation of nuclear power reactors to promote common defense and security and to protect health or minimize danger to life or property. NRC exercises this authority by issuing licenses, conditions to licenses, and rules / regulations and orders. If it becomes necessary to provide NRC with reasonable assurance of adequate protection of public health and safety or common defense and security, there is no dispute that NRC has the authority under the AEA to require licensees to conduct I
safeguards performance exercises. However, in order to impose an enforceable requirement to i
conduct these exercises, NRC must issue an order, license condition, or regulation. The NRC currently believes that the proper method of implementing that authority is through the use of regulations similar to the method used by the Office of Nuclear Materials Safety and Safeguards for requiring the conduct of exercises at fuel facilities (10 CFR 73.46).
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QUESTION 3.
Currently the OSRE exercises are conducted under the supervisic,n of the NRC, with NRC contractors who are security experts advising the mock adversary force on targets and methods of attack. The modified program would be run by the licensees.
(A)
Will the licensees determine how future drills are run, and will plant security forces know what targets will be attacked?
ANSWER.
Contrary to the implications of the question, OSRE exercises are not supervised or participated in by NRC staff or contractors. The drills and scenarios are established and conducted by the licensees. The NRC and contractors do observe and evaluate the exercises. The NRC comments on the appropriateness of the test and compares NRC's independent target selection against that of the licensee's to determine the adequacy of the exercise. As part of the rulemaking effort, NRC guidance on the implementation of exercises would be published and provide acceptable ways to conduct exercises. This guidance will state that drill participants will not have knowledge of the specific targats to be used in the drill.
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QUESTION 3.
Currently the OSRE e,tercises are conducted under the supervision of the NRC, with NRC contractors who are security experts advising the mock adversary force on targets and methods of attack. The modified program usaddbo um by the licensees.
(B)-
If so,is that a realistic simulation of a terrorist attack?
ANSWER.
Yes,in the modified program, the Heensees conduct the drills; therefore, the degree of realism is limited to the licensee's ability to simulate a terrorist attack. As we explained in our response q
I to the previous question, this is how the OSRE program is currently conducted. The need for J
support by the contractors during the transition period following completion of the OSREs and under the new rule, once completed, will be evaluated at a later date.
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QUESTION 4.
The press release also says the "NRC will likely continue to use private contractors to assist in its evaluation of the performance of its licensees during drms.srid exercises" (emphasis added)
(A)
Doths current NRC contractors for the OSRE program have security expertise that headquarters staff and regionalinspectors do not have?
ANSWER.
Yes, the NRC contractors for the OSRE program have extensive security expertise that headquarters staff and regionalinspectors do not have.
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QUESTION 4.
The press release also says the "NRC will likely continue to use private contractors to assist in its evaluation of the performance of its licensees during drlRs and exercises" (emphasis added)
(B)
Do you intend to conthue to use the current contractors or other contractors with equivalent security expertise? -
ANSWER.
The staff intends to continue using the current contractor during FY2000. The need for support by the contractors during the transition period following completion of the OSREs and under the new rule, once completed, will be evaluated at a later date.
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OUESTION 4.
The press release also says the "NRC will likely continue to use private contractors to assist in its evaluation of the performance of its licensees during drills and exercises" (emphasis added)
(C)
WE the contractors continue to advise the mock adversaries on how to attack the plants?
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4 ANSWER.
The NRC, through the use of staff and contractors, will continuo in its approach of critiquing exercise plans and independent target development to compare licensee targets as part of the process. This also enables the Scensee to conduct a more ree". tic exercise.
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I understand there has been some controversy over what should be the f
g standard for success in the drills. Licensees are required to protect
'against" radiological sabotage "
(A)
Do you think the drills should test the licensees' ability to protect against core damage or only against major radioactive release to the atmosphere?
ANSWER.
Title 10, Code of Federa/ Regulations (CFR), Section 73.55(a) requires that licensees be able l
to " protect against the design basis threat of radiological sabotage." Rad:ological sabotage is defined in Section 73.2 as, "any deliberate act directed against a plant or transport... which could directly or indirectly endanger the public health and safety by exposure to radiation."
. Therefore, the licensees are required io protect against acts that could endanger the public health and safety.
Part 73 does not define the limits of exposure that are considered dangerous for the public i
health and safety, although limits of exposure are discussed in various other sections of Title 10 of the CFR. The staff is currently considering how to clarify expectations in Part 73 and better define the term " radiological sabotage," calling on standards also used in other areas of nuclear l
icgulation, including Part 100. The systems and equipment necessary to prevent a radiological release, and therefore subject to protection by security measures, cold be dependent on the release definition. During the remaining OSREs, the teams will review this issue as part of their input to the NRC's Safeguards Performance Assessment Task Force.
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.p OUESTION 5.
I understand there has been some controversy over what should be the standard for success in the drills. Licensees are required to protect against " radiological sabotage."
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(B) in evaluating the drills, do you think it fair to assume that plant operators would act perfectly to prevent radioactive release, or should their performance be tested in the drills?
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NRC would expect operators to respond in accordance with training they have received in i
dealing with off-normal plant conditions. Operator actions need to be evaluated in as realistic a manner as practicable to simulate actual conditions. Operators are already routinely examined j
with respect to their response to off-normal plant conditions, regardless of the source of the l
condition. An important element of the proposed rulemaking and related guidance will be how i
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. to credit operator actions during an attempt at radiological sabotage. The remaining OSREs i
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will examine the integration of the overall actions by operations and security organizations in preventing radiological sabotage.
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OUESTION 6.
I would like to thank you for your recent letter responding to my letter on the Sunshine Act rules. In the letter you suggest that the Commission is
" legally prohlb/ted' from including under the Sunshine Act rules
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gatherings that do not meet the Supreme Court's narrow definition of a
" meeting."
(A)
Do you think the NRC's old rules are illegal and have been for the last 15 years since the Court's ruling?
ANSWER.
The Commission has never asserted that its former Sunshine Act rules were " illegal." Rather, it j
said that they did not follow sufficiently closely the intent of Congress, as explicated by the Supreme Court in /TT World Communications v. FCC,466 U.S. 463 (1984). As the American Bar Association pointed out in its report on the Sunshine Act, Congress can be presumed to have had a reason for amending the proposed Act to give federal agencies latitude to conduct many types of discussions outside the context of Sunshine Act " meetings." That reason was that Congress saw a positive value in such discussions and expected that federal agencies would hold them.
In its letter to you of July 19,1999, the Commission observed in a footnote that one decision of the United States Court of Appeals for the District of Columbia Circuit held that a federal l
agency acted beyond the scope of its authority when it promulgated a broader definition of l
- meetings" in its regulations than was contained in the Sunshine Act. WATCH v. FCC,665 l
F.2d 1264 (D.C. Cir.1981). One can only speculate as to whether a similar challenge to the NRC's original Sunshine Act regulations would have yielded a similar result.
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QUESTION 6.
(B) is there anything in the Sunshine Act or in other laws that actually prevents Commission gatherings from being open to the public?
ANSWER.
There may be a number of areas where the Commission could be legally constrained from
. holding a discussion in public, e.g., national security information or information subject to the Privacy Act.
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QUESTION 6.
(C) is the Commission legally allowed to keep transcripts or recordings of all gatherings of a majority of the Commission?
ANSWERS.
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We know of no barrier to the Commission's keeping transcripts or recordings of any discussions among any number of Commissioners.
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3 OUESTION 7.
The revised rule is intended to foster general discussions by the Commission that do not now take place by allowing them to be secret.
1 (A)
Why can't the Commission hold such discussions in public?
ANSWER.
There is no legal barrier perse to such discussions. That does not mean, however, that the statute lacks an inhibiting effect. The Commission can only rep.aat the words of a unanimous Supreme Court in the ITTease:
i Congress in drafting the Act's definition of " meeting" recognized that the administrative process cannot be conducted entirely in the public eye. "[l]nformal background discussions [that) clarify issues and expose varying views" are a necessary part of an agency's work. [ Citation omitted.] The Act's procedural requirements effectively would prevent such discussions and thereby impair normal agency operations without achieving significant public benefit. Section 552b(a)(2) therefore limits the Act's application....
l 466 U.S. 463,469-70.
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QUESTION 7..
(B) is there anything in the old rules that would prevent this?
1 ANSWER.
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- Nothing in the NRC's former Sunshine Act rules would prevent it from holding any discussions it wished to in public, as long as the discussions do not involve information that the Commission is legally constrained from discussing in public.
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QUESTION 8.
(A)
Under the revised rule, could the Commission meet to discuss how easing government regulations could assist the nuclear power industry, and do so without public notice or public participation and without any transcript, tape, or minutes of the meeting?
ANSWER.
The hypothetical topic proposed in the question likely would, under the Commission's revised
- rules, fallinto the category of discussions "sufficiently focused on discrete proposals as to cause or be likely to cause the individual participating members to form reasonably firm positions regarding matters pending or likely to arise before the agency," and thus fall into the category of topics that can be discussed only in " meetings"if three or more Commissioners are present.
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QUESTION 8.
(B)
Could the rules be revised in six months so that no record would be kept that such a meeting took place?
ANSWER.
l The question is moot; see (a).
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QUESTION S.
(C)
If discussion of specific proposals for changing NRC regulations took place at such a meeting, or if the Commission made secret decisions at such a meeting, how would the public find out?
ANSWER.
Again, the question is moot; see (a).
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OUESTION 9.
Do you think that secret Commission discussions'will " enhance public l-
- confidence"in the NRC's work? If so, how?
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ANSWER.
. In its July 1999 Federal Register notice, the Commission addressed this point. It acknowledged l
the possibility that the NRC's action would diminish public confidence in the Commission, but stated that it believed "that the legal and policy reasons for its action - compliance with the Supreme Court's guidance, and the expected benefits in collegiality and efficiency, make this a l
desirable course of action, even if -- despite the Commission's best efforts to explain its reasoning -- some persons misunderstand or disapprove of the Commission's action." The Commission added: "It is also possible that the potential enhancement of collegiality and the potential improvement in Commission decision-making that may result from non-Sunshine Act discussions will ultimately increase the public's confidence in the Commission's actions."
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QUESTION.10.
I understand that the NRC has recently conducted Fire Protection l
Functional inspections at several plants. Could you please summarize results of these inspections and identify the frequency of significant
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I ANSWER.
The NRC pedormed three full-scope fire protection functional inspections (FPFI); one at River Bend Station, one at Susquehanna, and one at St Lucie. In addition, one reduced-scope FPFI, using inspection techniques developed for the full-scope inspections, was conducted on a licensee's fire protection program self-assessment at Prairie Island. At each inspection the staff found deficiencies in the licensee's program implementation which could result in weakening fire protection defense in depth. However, the NRC also found that licensee self-assessments using the fire protection inspection and assessment guidance established by the FPFI program j
were capable of identifying programmatic strengths and weaknesses.
Examples of the deficiencies found in the inspections include such things as control of transient combustibles, weak fire brigade performance, compliance with design codes and standards for fire protection systems, and weaknesses in post-fire safe shutdown analysis and implementation. In each case, compensatory measures such as interim post-fire safe shutdown contingency plans or fire watches were put in place to mitigate the possible reduction in defense in depth while corrective actions were being implemented. These fire protection compensatory measures are to be maintained in effect until the inspection findings are resolved end/or final corrective actions are taken by the licensee organization.
QUESTION 10. (Cont.)'
After the pilot FPFis, the NRC staff conducted a public workshop with the reactor licensees to discuss the results of the FPFis and the lessons leamed from the FPFI program. One of the results of the FPFI program was renewed industry attention to nuclear power plant fire safety.
As examples, the Nuclear Energy Institute is developing performance indicators for reactor fire protection and new procedures that will help the licensees conduct self-assessments of their fire protection programs. In addition, some licensees, including those that were not subject to FPFis, have made voluntary changes to their fire protection programs and have conducted self-assessments in response to the lessons learned from the FPFI program. As a result of the i
FPFI program, the NRC staff concluded that it should continue to monitor licensee performance in this area and included reactor fire protection in the new reactor oversight and inspection program. This new program includes new risk-informed fire protection inspection procedures and a newly-developed tool for assessing the risk and safety significance of fire protection deficiencies. The staff believes that the expected increase in licensee self-assessments, coupled with the more frequent and robust NRC fire protection inspections that it will conduct under the new reactor oversight and inspection program, will ensure an adequate level of fire protection at all nuclear power plants.
Additional /Backoround Information.
Fire protection program implementation findings are documented in the following inspection reports:
River Bend FPFI - NRC Inspection Report Number 50-458/97-201 dated March 20, 1998.
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QUESTION 10. (Cont.) -
l Susquehanna FPFI - NRC Inspection Report Numbers 50-387/97-201 and 50-388/97-201 dated May 13,1998.
St. Lucio FPFI - NRC inspection Report Numbers 50-355/98-201 and 50-389/98-201 dated July 9,1998.
Prairie Island FPFI - NRC Inspection Report Numbers 50-282/98-016 and 50 306/98-016 dated October 9,1998.
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l OUESTION 11.
I understand that plants have recently done assessments of the risk of fire-induced core damage.
I (A)
What is the range of core damage frequency estimated at the different plants?
t ANSWER.
The values reported by licensees for fire induced core damage frequency (CDF) range from d
2x10 to 4x10 per reactor year.
Backaround/ Additional Information.
Quad Cities initially reported a fire induced CDF of 5x10'8 per reactor year in their original submittal dated February 17,1997. The reported value in its revised submittal dated May 27, 1999,!s 6x10-s per reactor year. The revised submittal is currently under review by the staff.
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I understand that plants have recently done assessments of the risk of fire-induced core damage.
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.(B) is most of Das range due to plant differences or to differences in l
risk assessment methods and assumptions?
ANSWER.
The vintage and layout of a given plant contribute to the differences to a certain extent; however, some of the variability can be attributed to differences in methods and assumptions
' employed in the analysis. The staff is currently working on identifying, analyzing and reducing sources of variability in fire risk assessments.
Backaround/ Additional Information.
Although different methods and assumptions can result in significant variability in the fire induced core damage frequency (CDF) estimates, the relative ranking of fire scenarios and dominant fire areas at a plant are based on relative values of CDF and not the absolute values.
The major objective of the IndMdualPlant Examination of External Events'(IPEEE) program was not to develop accurate CDF estimates. Rather, the major objectives were for licensees to:
(1) Develop an appreciation of severe accident behavior, (2) Understand the most likely severe accident sequences that could occur at the plant, (3) Gain a qualitative understanding of the overaillikelihood of core damage, and (4) Reduce, if necessary, the overall likelihood of core damage by modifying, where appropriate, hardware and procedures that would help prevent or mitigate severe accidents. -
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Given the apparent lack of quality control, how can the NRC implement a risk-informed inspection program for fire protection next year when standards for fire risk assessments will not be available until some years later?
ANSWER.
Currently available risk information (generic and plant-specific) and risk assessment techniques (e.g., those used by the Ilcensees to perform the fire analyses of the individual plant examination of extemal events (IPEEE)) and risk assessments (e.g., the results of the plant-specific lPEEE fire analyses) are adequate to support r k informed reactor fire protection inspections to a limited extent. In the future, as risk assessment methods improve and mature, and additional experience is gained with their applica Son, additional risk insights will be incorporated into the NRC fire protection inspection program.
The NRC's new reactor inspection and oversight program includes a baseline fire protection inspection program that is based on long standing fire protection and post-fire safe shutdown inspection techniques. These techniques include both deterministic and risk assessment techniques designed to ensure that licensees have adequately implemented their fire protection programs and that they provide a sufficient level of fire safety to maintain one train of safe shutdown capability free of fire damage.
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During the fire protection functional inspection program, the NRC used fire risk insights from the plant IPEEEs to focus the inspections on those plant areas that present the highes; 4k from a l
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m-QUESTION 12. (Cont.)
reactor safety perspective. This same basic approach has been incorporated into the new besoline fire protection inspection program.
In addition, under the new reactor inspection ano oversight program, the NRC has developed sn inspection finding significance determination process. This process, which includes both deterministic and risk assessment elements, will be used by the NRC and the licensees to evaluate fire protection findings, assess their risk impact, and estimate any potential change in risk they may have on the core damage frequency. Through the implementation of this method, NRC focus can be applied to important fire protection findings and their resolution.
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l-QUEST 10N 13.
The NRC has strict rules regarding drug # as and drug testing for personnel at nuclear power plants but only vague guidelines regarding overtime and consequent fatigue, which can cause simliar symptoms. As a consequence, it is common for plant personnel to work several 70 hour8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br /> weeks in succession.
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. Why does it not make sense to have strict, enforceable rules on working hours, as there are for drugs (and as there are on working hours for airline pilots and truck drivers)?
l ANSWER.
i By letter dated May 18,1999, the NRC responded to a previous inquiry by you and Congressmen Dingell and Klink on this matter. In that response we indicated that we would be reassessing the Commission's " Policy on Factors Causing Fatigue of Operating Personnel at Nuclear Power Plants." The reassessment process is expected to provide a basis for making a Jatermination conceming whether the policy should be reaffirmed, revised, or alternative regulatory approaches, such as rulemaking on working hours, should be pursued. The reassessment is scheduled to be completed by the end of FY 2000.- (See also the response to Question 14.)
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OUESTION 14.
. Given that the NRC is aware of more than one hundred cases of excess overtime without required approval (and has no records of overtime l
worked with approval), and given that it is difficult to determine the effect
' of fatigue on safety incidents, why does the NRC plan not to review licensee use of overtime?
ANSWER.
During the development of the NRC's revised reactor oversight process, the NRC made the decision not to include monitoring of overtime use. This decision was based on the lack of risk significant findings from past inspections and event investigations related to working hours and
. is consistent with the NRC's effort to focus inspections on risk-significant issues. However, as part of the revised reactor oversight process, if performance indicators and inspection findings indicate problems, licensees are expected to determine the root cause of those problems. If the root cause is in the area of human performance, fatigue is one of the many possible contributing factors. NRC inspections are conducted to assure that licensees are implementing
' effective corrective action. In addition, and as noted in response to Question 13, the NRC is initiating a reassessment of the policy to ensure that NRC regulatory actions are consistent with the risk-significance of this issue. The results of this reassessment will be considered in L
making any determination concoming the NRC's inspection program as it relates to use of overtime'and potential personnel Impairment from fatigue.
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l QUESTION 15.
The Commission' recently reversed a decision to provide funding for state stockpiles of potassium iodide (KI), which had been intended to help.
l protect the public in the event of a nuclear accident. According to a
~ June 15,1999 letter from Chairman Jackson to the Federal Emergency Management Administration (FEMA), the reversal was in part based on a
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1980 NRC policy.
i (A) is there any legal barrier to the Commission funding purchases of Kl for states that wish to establish stockpiles?
ANSWER.
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There is no per se legal barrier to the Commission funding the purchase of Kl for the states that Wish to establish stockpiles. The Commission determined as a policy matter that the NRC will not fund the purchase of Kl for the states. This decision is consistent with the Commission's l
bngstanding policy that funding for state and local emergency response measures has been l
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the responsibility of those govemments working with the licensees. The Commission believes that the overall cost of Kl is minimal when placed in the context of emergency planning.
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As a separate matter, the Commission determined as a policy matter that the federal govemment should fund regional stockpiles of Kl. The Commission stated that well placed federal stockpiles, en addition to any state stockpiles, is a measure the federal government should consider. Not every state will elect to have a stockpile (see Answer 16(A)). Because i
states are not required to stockpile, the NRC believes that regional stockplies may be a prudent and reasonable approach to making Kl available to emergency response officials in the very I
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T QUESTION 15. (Cont.)
l-unlikely event of a severe reactor accident. These regional stockpiles could be used to supplement local stockpiles, or when a state without a stockpile decides to use Kl on an ad hoc
' basisIn a nuclear emergency. If Congressionally approved appropriations for NRC funding i
were sufficient, NRC could consider assisting in the funding of purchasing Kl for regional stockpiles.
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Question 15 (B).
if there are policy barriers, has the NRC reexamined those policies?
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1 ANSWER.
The NRC and FEMA are currently reexamining earlier positions and policies regarding Kl. The goal is to identify the options available to the two agencies to make Kl available to the states.
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. QUESTION 16.
The Commission, in its reversal, also referred to concerns about cost.
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(A)
How much money would it cost to fund the purchase of Kl for all states?
j ANSWER. -
In Commission paper SECY-98-264 dated November 10,1998, the estimated cost of purchasing a supply of KI was between $117K, for two to three states, and $3.25M for all states with nuclear power plants. These estimates do not include refurnishing every seven years, as l
would be reguired due to its shelf life. The cost for funding the purchase of Kl depends on the current market price of KI tablets and the number of states that would request state stockpiles.
In November 1998, tne staff reported an increase in the price of Kl tablets.
l The Commission considered the cost to fund all state stockpiles, which, as indicated above, 4
would be about $3.25M in a given year, with replacements necessary every seven years, in the context of the overall budget. The NRC's budget, adjusted for inflation, is the lowest it has been in more than 20 years. The resources to fund state stockpiles are not budgeted and would have to be reprogrammed from existing agency programs. As you know, the House is recommending a $10M reduction in the appropriation for FY2000 recommended by the l
President. Egg H.R. 2605, Title IV. For these reasons, the Commission's concerns about l
costs were considered in the context of how best to spend limited NRC funds to produce the most comprehensive and effective national Kl program. (See Answer 15).
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QUESTION 16..-
- (B)
How much money has the NRC spent studying the Ki lasue since -
L<
- 198971 l
l ANSWER.
l, The total amount of NRC spending on the Kl issue exceeds $2.6M for last 10 years (1989 -
L 1999), based on a conservative estimation in two components:
. (1) ' !Approximately 20 FTEs ($2M) of NRC staff was expended during the period of 10 years, with an additional $240K for Rulemaking and support work'from October 1998 to August 11,1999.
(2)
$300K was used for a contractor's fee for study and publication of NUREG/CR-6310, on "An Analysis of Potassium lodide (KI) Prophylaxis for the General Public in the Event
)
of a Nuclear Accident," which was issued in 1995. The additional NRC staff support for the NUREG/CR-6310 was.1 FTE ($100K) for FY91-96.
I l
This question, in the context of the series of questions on this issue seems to suggest that the NRC could have better spent the resources it has used over the past 10 years researching and' j
developing a Kl policy on funding state KI stockpiles. Funding for researching and developing a KI policy is a separate matter from funding state stockpiles.
Just as the NRC was ruquired to do in the past, the NRC will need to dedicate future resources to devskping and finalizing chang'es to NRC regulations and making final changes to a national policy on KI. Cpecifically, funds will need to be expended to complete the NRC rulemaking t
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L QUESTION 16. (Cont.)
]
i requiring licensees to consider using KI as part of their emergency planning, and to continue working with FEMA and other agencies represented on the Federal Radiological Preparedness Coordinating Committee (FRPCC), to re-evaluate the Federal policy on Kl. These resource i
expenditures are over and above the additional cost of funding state stockpiles.
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QUESTION 17.
The Commission now supports regional Ki stockpiles. However, the i
Director of the (FEMA) stated in a April 29,1999 letter to the NRC that
' such stockpiles would " complicate, not strengthen radiological emergency
_ preparedness." The Commission, in its dispute with the EPA over radiation release standards, emphasized its superior expertise.
1
-(A)
How many emergency preparedness experts does the NRC have~
l
' on staff, and how many does FEMA have on staff?
4 ANSWER.
l' NRC has about 40 specialists for emergency preparedness and response in its headquarters and four regions including a Regional State Liaison Officer in each region who serves as the NRC representative on the FEMA Regional Assistance Committees that assist state and local j
govemment officials in emergency planning, in addition, NRC has a significant number of nuclear and radiological health scientists, reactor and radiological inspectors, and other technical specialists on its staff. FEMA has approximately 90 specialists in its radiological emergency preparedness program in headquarters and 9 regions with nuclear power plants.
)
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NRC and FEMA have been working together since the TMI accident in emergency planning, l
exercises, and response and have developed complementary roles and responsibilities. The l
roles and responsibilities of the NRC and FEMA for radiological emergency preparedness are defined in NRC and FEMA regulations (10 CFR 50 and 44 CFR 350, respectively) and in a Memorandum of Understanding between the two agencies. The NRC is icsponsible for making radiological health and safety decisions with regard to the overall status of emergency 4
L
QUESTION 17A.
i preparedness, and for reactor licensee oversight and response to rad lological events onsite and within the physical and radioloD cal boundaries of the reactor facility. FEMA provides support i
functions to NRC during emergency situations and is responsible for offsite coordination of emergency management with state and local govemments in the jurisdictions surrounding the reactor facility. NRC has significant resources and expertise in both technical and radiological areas to deal with reactor operations and events. FEMA provides specialities dealing with emergency management and associated logistics, particularly, for coordination with state and i
local govemments and generalpopulation.
The Commission has directed the NRC staff to work with FEMA to establish and resolve an appropriate policy on Ki use and stockpile issues, i
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L QUESTION 17.,
(B)
..Why do you dispute FEMA's conclusions regarding Kl stockpiles?
h ANSWER.
i l The NRC and FEMA are in agreementon many aspects of tho' Kl issue. On June 14, the Commission published a proposed rule requiring licensees to consider, as part of their l
emergency planning, the prophylactic use of KI as a supplement to evacuation and sheltering.
See Proposed Rule,64 Fed. Reg. 31,737. Both the NRC and FEMA agree that the states will make the final decision whether to include Ki for the general public in their emergency preparedness (EP) programs. The Commission believes tha*. ' a overall cost of KI is minimal
. when placed in the context of emergency planning.
i However, as we state'in response to Questie-WA), because states are not required to stockpile, the NRC believes that regional stov
- s may be a prudent and reasonable approach p
to making Kl available to emergency response officials in the very unlikely event of a severe reactor accident that includes a significant early radiolodine component. The NRC is confident, based on a long record of coordination and cooperation between the two agencies, that the
~ NRC and FEMA staffs will successfully resolve the Kl stockpile issue.
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g QUESTION 18.
How much radioactive solid materials by volume and by radioactivity have been released or cleared from regulatory control i
I either on a " case-by-case" basis or through other exemption processes?
ANSWER.
The NRC has approved specific releases of solid material on a case-by-case basis from NRC facilities. Over the past year, these releases include an estimated 5000 metric tons of calcium fluoride with a low enriched uranium activity of approximately 3 pCVg and an estimated 175,280 pounds of calcium fluoride with a natural uranium activity of approximately 7 pCVg. In both cases, there would be little, if any impact to workers or members of the public.
l To put these releases in perspective, the Environmental Protection Agency encourages the l
recycling of coal ash, with a natural uranium activity that may be an order of magnitude or more higher,in building materials. Naturally occurring radioactive materials at these or higher levels can also be four m fertilizers and other consumer products.
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QUESTION 19.
How much NRC resources (budget and staff, including cantracts) have been and are projected to be used to issue standards for clearance or release of radioactive material from regulatory control?
ANSWER.
i Prior to FY 1999, NRC expended $2.6 million contract support to develop NUREG-1640,
" Radiological Assessments for Clearance of Equipment and Materials from Nuclear Facilities" for use in developing regulations. This report contains the technical basis for calculating doses from release of solid materials.
NRC has budgeted an additional $6.5 million (30 FTE and $3.5 million contract support) over the next 3 % years to develop regulations, if necessary.
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l QUESTION 20.
In an attachment to a May 3,1999 letter to me, NRC staff noted that "The i
NRC regulatory oversight and authority does not extend to the U.S.
l offsite electrical grid system," and that "FERC and NERC have not identified to the NRC the need to keep particular nuclear power plants running during the Y2K transition."
(A)
If the NRC's mandate is the public health and safety at nuclear power plants, and no specific need for power has been identified, why does the NRC propose to allow licensee to violate health-based regulations in order to increase stability of the grid?
ANSWER.
The NRC does not propose to allow licens,ees to violate health-based regulations. If there is a need for power, the NRC proposes to exercise discretion upon balancing the need for power with the public health and safety or common defense and security of not opsialing against potential radiological or other hazards associated with continued operation. The NRC will exercise discretion only when it is clearly satisfied that safety will not be unacceptably affected by exercising the discretion.
The NRC enforcement policy allows the exercise of enforcement discretion in certain situations to allow continued plant operation when it does not present an undue risk to public health and safety and is in the public interest. This is consistent with NRC's mandate to assure public health and safety.
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QUESTION 20.(A)
The following is a summary of the interim enforcement policy published in the Federal Register l
cf Friday, July 30,1999 (64 Fed. Reg. 41474) that will govern the exercise of enforcement discretion by the NRC staff. The policy would be implemented when licensees of oporating.
nuclear power plants find it necessary to deviate from license onditions, including technical specifications (TSs), in those cases in which Y2K-related complications would otherwise require a plant shutdown that could adversely affect the stability and reliability of the electrical power grid.This policy does not extend to situations in which a licensee may be unable to communicate with the NRC. The policy is effective August 30,1999 and will remain.'n effect through January 1,2001. This policy only applies during Y2K transition or rollover' periods (December 31,1999, through January 3,2000; February 28,2000, through March 1,2000; and December 30,2000, through January 1,2001). During these periods, a licensee may contact the NRC Headquarters Operations Center and seek NRC enforcement discretion with regard to the potential noncompliance with license conditions, including TSs, if the licensee has determined that:
(a)
Complying with license conditions, including TSs, in a Y2K-related situation would require a plant shutdown; (b)
Continued plant operation is needed to iielp maintain a reliable and stable grid; and
-(c)
Any decrease in safety as a result of continued plant operation is small l
(considering both risk and deterministic aspects), and reasonable assurance of
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QUESTION 20fA) i public health and safety, the environment, and security is maintained with the enforcement discretion.
Licensees are expected to follow the existing guidance as stated in NRC Inspection Manual Part 9900 for Notices of Enforcement Discretion to the maximum extent practicable, particularly regarding a safety determination and notification of NRC. A licensee seeking NRC enforcement discretion must provide a written justification, or in circumstances in which good cause is shown, an oral justification followed as soon as possible by written justification. The justification must document the need and safety basis for the request and provide whatever other information the NRC staff needs to make a decision regarding whether the exercise of discretion is appropriate. The NRC staff may exercise enforcement discretion on the basis of balancina the oublic health and safety or ccmmon defense and security of not operatina aaainst potential radioloaical or other hazards associated with continued operation. and a determination that safety will not be unacceptably affected by exercisina the discretion. The Director of the Office of Nuclear Reactor Regulation, or designee, will advise the licensee whether the NRC has approved the licensee's request and, if so, will subsequently confirm the exercise of discretion in writing.
Enforcement discretion will only be exercised if the NRC staff is clearly satisfied that the action is consistent with protecting public health and safety and is warranted in the circumstances presented by the licensee.
Although the NRC's oversight of the electric grid system does not extend into the design and operation of the entire grid, it covers the design and operation of the grid at its interface with the l
QUESTION 20.fAl i
nuclear power plant, since the offsite power, system is the primary and preferred source of power for the functioning of structu.es, systems, and components important to safety.
Although NERC has not identified the need to keep specific nuclear power plants running during Y2K transitions, the need to have many types of generating units and sufficient reserve capacity on line as a precaution against Y2K events has been identified. Should a Y2K problem lead to the common-cause system or device failure and consequent loss of a particular group of generation facilities, such as gas-fueled generation stations, then the remaining mix of generation units and reserves would need to make-up the loss. Nuclear units operating during the Y2K transitions have been factored into the overall strategy for preparing the electric power systems of North America for transition into the year 2000.
I
QUESTION 20.
In an attachment to a May 3,1999 letter to me, NRC staff noted that "The NRC regulatory oversight and authority does not extend to the U.S.
offsite electrical grid system," and that "FERC and NERC have not identified to the NRC the need to keep particular nuclear power plants running during the Y2K transition."
(B)
How will the NRC evaluate a licensee's oral justification that is delivered by phone?
ANSWER.
During the Y2K transition, in support of the regulatory response facet of the NRC Y2K Contingency Plan, the appropriate NRC staff will be available at the NRC Headquarters Operation Center, prepared to process enforcement discretion requests related to the Y2K problem. As stated in the summary of the interim enforcement policy above, an oral justification supporting the licensee request for an enforcement discretion must be followed by a written justificatiort Based on the staff's evaluation of licensee request and justification, the Director of Nuclear Reactor Regulation, or designee, will orally advise the licensee whether the NRC will exercise enforcement discretion, and, if so, will subsequently confirm with a written a notice of enforcement discretion. The NRC will also have inspectors at all nuclear power plant sites to f
- provide on-site evaluation of the licensee's requests and justifications.
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F 1
OUESTION 21.
.(A)-
How will cleanups differ, and at what types of sites, if the cleanup l
j standards are those favored by the NRC vs. those proposed by the EPA?
ANSWER.
. NRC published a final rule establishing radiological criteria for decommissioning in July 1997.
This rule established 25 millirem per year (mrem /yr) from all potential exposure pathways as the I
acceptable criterion for release of licensed sites for unrestricted use. This dose limit is coupled with the provision that the' dose he As Low As is Reasonably Achievable (ALARA). EPA believes that this is not protective of the public health and the environment and stated that 15 mrem /yr from all pathways, with separate limits established for groundwater, is acceptable. The EPA limits on groundwater would be the maximum contaminant levels (MCLs) specified in 40 CFR 141, National Primary Drinking Water Regulations. We note that EPA has not promulgated its 15 mrem /yr standard nor its position that drinking water MCLs should be applied to groundwater by rulemaking. It has done so by guidance documents not subject to an Administrative Procedure Act rulemaking process. A proposed rule was withdrawn by the EPA J
. In December 1996 when it was heavily criticized in the interagency discussions conducted by the OMB's Office of information and Regulatory Affairs.
- The NRC has taken the position (Chairman Jackson letter to Senator John H. Chafee, dated July 16,1998) that a 25 mrem /yr all-pathways dose criterion provides a dependable, risk-based i
regulation that is consistent with the recommendations of national and intemational scientific
, organizations. The NRC has performed extensive cost-benefit analyses for the application of MCLs for radionuclides in groundwater at, or near, decommissioned sites in the voluminous y
/
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QUESTION 21 A. (Cont.)
J generic environmental impact statement that accompanied the rule and has found that it is not appropriate. For example, strontium-90 remediation by the pump and treat method to achieve the current EPA MCL of 0.06 mrem /yr would cost $23 billion / death averted according to the GEIS.
EPA has neither established, nor proposed, a generally applicable environmental standard for -
the cleanup of radiologically contaminated sites. EPA has provided guidance that an all-pathways standard of 15 mrem /yr, in conjunction with a separate groundwater standard based on the maximum contaminant levels (MCLs) established under the Safe Drinking Water Act, should be applied to such sites. Although concentration goals for cleanup are site, radionuclide, and scenario dependent, under NRC regulations. given the same exposure scenario and assumptions, the cleanup of building surfaces, soil and/or groundwater would likely be marginally less by an insignificant amount from the public health and safety perspective. In addition, in these cases, less low-level radioactive waste would be generated.
In addition, it is likely that imposition with the MCLs would require more complex final surveys to demonstrate compliance for some sites and potentially great costs for no safety benefit.
Indeed, the GEIS found potential net negative health effects for soll cleanup to EPA levels at reference facilities because the marginal safety benefits of removing slightly radioactive soil in
. large quantities are more than offset by the negative health effects of transporting the material.
l In some cases, compliance with the MCLs could require additional groundwater treatment that would not be required under the NRC regulation. Such treatment could significantly delay the completion of decommissioning. In other cases, use of MCLs may be less protective than NRC's all-pathways standard because: the MCLs are based on a modeling approach that has i
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o QUESTION 21 A. (Cont.)
not been updated since 1963 to reflect the current technology on the uptake and potential doses resulting from ingestion of radionuclides through drinking water; MCL requirements do not cover all radionuclides; and the use of MCls would not provide a consistent risk standard for different radionuclides because the dose' at the current MCLs" can range from 0.01 millirem / year for the radionuclide promethium-147 to 30 millirem / year for thorium-232.
Affected facilities would include a cross-section of medical, academic, and industrial facilities; fuel cycle facilities; research reactors; and power reactors.
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' Calculated using EPA-570/9-76-003, " National Primary Drinking Water Regulations,"
Appendix B methodology.
- Calculated using EPA-520/1-88-020," Federal Guidance Report No.11," Dose Conversion Factors for Ingestion.
k QUESTION 21.
'(B)
At what fraction of NRC-licensed facilities would the cleanups be l.
affected?
t i
ANSWER.
L
- Based on a review of the types of licensees that would be required to submit a
{
l decommissioning plan to NRC for approval prior to license termination, approximately 40% of
- NRC-licensed facilities required to submit a decommissioning plan could be affected.. It is l
estimated that the same percentage of Agreement State facilities would also be affected.
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QUESTION 21.
'(C)
~ Are these sites almost exclusively long-closed sites with historical releases?.
ANSWER.
No. Affected facilities are predominantly operating medical, academic, and industrial facilities; fuel cycle facilities; research reactors; and power reactors in addition to closed, but still -
licensed, facilities.
s Markey/NMSS 09/9/99 e
QUESTION 22.
(A) is the dispute between the EPA and the NRC solely that of a 15 mrem standard versus a 25 mrem standard?
ANSWER.
No, the disagreement between the EPA and the NRC is broader than that of a 15 mrem standard versus a 25 mrem standard. The agencies also disagree on the need to demonstrate compliance with standards for individual pathways (e.g., drinking water / groundwater) versus demonstration of compliance with an all-pathways standard.
The NRC has taken the position (Chairman Jackson letter to Senator John H. Chafee, dated July 16,1998) that 25 mrem /yr all-pathways dose criterion provides a dependable, risk based regulation that is consistent with the recommendations of national and international scientific organizations. The EPA faults the NRC for not establishing a separate, specific requirement for the groundwater pathway that incorporates requirements to meet specified maximum contaminant levels (MCLs). The NRC has performed extensive cost-benefit analyses for the application of MCLs for radionuclideo in groundwater at or near decommissioned sites in the voluminous GEIS that accompanied NRC's rule and has found that it is not appropriate. For example, Sr-90 remediation by the pump and treat method to achieve the current EPA MCL of 0.06 mrem /yr would cost $23 billion / death averted according to the GEIS. The NRC also believes that in some instances the application of MCLs in groundwater may be less protective
- than NRC's all-pathways standard because: (1) the MCLs are based on a modeling approach that has not been updated in over 30 years, (2) MCL requirements do not cover all I
radionuclides, and (3) MCLs do not provide a consistent risk basis for license termination or waste disposal.
e
. QUESTION 22A. (Cont.) '
The health effects of 15 mrem /yr versus 25 mrem /yr are often characterized by EPA as a d
2x10 (2E-4) difference in lifetime cancer mortality. This is based on a linear no threshold model for estimating the effects of radiation, which national and intemational advisory bodies recommend be used by regulators. However, these bodies also recognize that applying the j
model at low doses and low dose rates is a very large extrapolation from where health effects have actually been demonstrated, primarily in Hiroshima and Nagasaki survivors who received more than 20,000 mrem in a very short time period. That is why they recommend a 100 i
mrem /yr public dose limit and the use of constraints on the order of 25-30 mrem /yr within that limit for exposures to any individual source of radioactivity. The advisory bodies recognize the possibility that there is potentially no health benefit in reducing exposures at these very low
- levels, less than 10% of natural background radiation.
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l.
i-QUESTION 22.
(B)
What other aspects of the site release standards could be affected by the proposed amendment?
ANSWER.
The proposed amendment would allow licensees to demonstrate compliance with a single all-pathways individual dose limit versus demonstration of compliance with two standards, an all-
. pathways standard and an individual pathway standard (e.g., groundwater).
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QUESTION 22.
'(C)
Do the EPA and the NRC disagree on the degree of risk exposed IndMduals should undergo, on the risk posed by a given level of radiation, or both?
L ANSWER. -
The NRC and the EPA generally agree on the risk posed by a given level of radiation and on i
the maximum total dose to an individual from all sources (i.e.,100 mrem /yr), although the NRC believes that there is great uncertainty of the rie):, if any, posed by low levels of radiation.
i However, the NRC and the EPA disagree on the degree of risk that is acceptable for exposed 1
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Individuals from a single source. For example, the NRC has proposed an annual, all-pathway, individual dose limit of 25 mrem /yr (1.25 x 10 annual risk of fatal cancer) in its proposed j
4 regulations for disposal of high-level waste at Yucca Mountain (10 CFR Part 63) and in its final regulation establishing radiological criteria for license termination (10 CFR Part 20 Subpart E).
The EPA has commented that NRC's regulation is not protective and recommends the Individual dose limit be reduced to 15 mrem /prp.5 x 10 annual risk of fatal cancer). However, 4
although the risk levels are different, because of the uncertainty in the linear no threshold hypothesis and the risk estimates themselves, the NRC believes that 25 mrem /yr is fully protective of public health and safety.
The EPA and the NRC also disagree on the need for separate requirements (i.e., maximum contaminant levels or MCLs) to protect groundwater. NRC believes that an all-pathway dose
. limit protects individuals from all pathways including groundwater. Thus, NRC considers l
separate requirements for groundwater protection unnecessary. Additiondy, protection of u
j groundwater, at levels dictated by MCLs for any organ, can require a level of protection more I
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QUESTION 220.
1han 100 times more restrictive than the all-pathway dose limit (e.g., the MCL for lodine-129
- dose to the thyroid contributes only 0.1 mrom/yr to the individual dose limit of 25 mrem /yr).
hlRC is not aware of any health and safety basis for limiting annual dose to fractions of a millirem.
The NRC fully considered the 15 mrem /yr versus 25 mrem /yr all-pathways standard in its rulemaking on the license termination rule. A majority of commenters suggested a 25 mrem /yr or higher standard. Other commenters supported essentially a zero standard -- no radiation above background should re;nain. EPA was almost unique in supporting 15 mrern/yr. As noted above, international and national standards bodies recommend 25-30 mrem /yr as a constraint for any given exposure within an overall 100 mrem /yr public dose standard. Also as roted above, the voluminous GEIS accompanying the NRC rule demonstrated very large costs for very little benefit in reducing the decommissioning unrestricted release standard from 25 mremlyr to the APA's proposed 15 mrem /yr plus groundwater application of MCLs. Indeed, in many cases there was a net negative health effect as a result of the additional cleanup.
[
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l -
OUESTION 23.
(A)
Would releases from any sites under NRC's proposed standards L
I likely exceed maximum contaminant levels permitted under the Safe Drinking Water Act?
l-ANSWER.
L Because NRC's regulation is an all-pathways dose limit, and this regulation exceeds some of 1he MCLs,it is possible that releases from some sites under the NRC standard could exceed the maximum contaminant levels.
i -
Compliance with the maximum contaminant levels (MCLs) can be very restrictive because:
(1) MCLs for certain radionuclides limit doses to levels significantly below NRC's proposed all-pathway dose limit (e.g., the MCL for iodine-129 is limited by the dose to the thyroid, which contributes only 0.1 mrem /yr to the all-pathways individual dose limit of 25 mrem /yr), and (2) EPA has applied groundwater protection requirements to small volumes of water (i.e.,
applied to any portion of a special source of ground water), rather than to water that is indeed
' Ekely to be consumed as drinking water.
The NRC also believes that the application of radionuclides in groundwater may be less protective than the NRC's all-pathways regulation because: (1) the MCLs are based on a i
l
. modeling approach that has not been updated in over 30 years, (2) MCL requirements do not cover all radionuclides,~ and (3)' MCLs do not provide a consistent risk basis for license termination or waste disposal.
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QUESTION 23A. (Cont.)
For the proposed high-level waste repository at Yucca Mountain, application of MCLs to small volumes of water (e.g.,10 acro-ft or approximately 12 thousand cubic meters) could require the repository to be, in assence, azero-release facility. It would be difficult 'or the Department of Energy to demonstrate zero releases over the proposed compliance period of 10,000 years at I
_ any site, except for a site in natural salt formations which generally have no potable groundwater associated with them. For example, the groundwater issue did not arise at the l~
Waste isolation Pilot Plant because of the absence of potable groundwater at that facility.
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QUESTION 23.
'(B)
How would this arise?
ANSWER.
i For decommissioning sitas, MCI.s could be exceeded at sites where groundwater is the principal exposure pathway. In the high-level waste repository program, MCLs could be exceeded in several situations. First, MCLs could be exceeded if the compliance demonstration is required to assume a small volume of water is mixed with releases from a relatively small number of waste packages (e.g. approximately 10 waste packages). Conversely, MCLs could be exceeded if releases from a larger number of containers (i.e., hundreds of waste packages or a few percent of the total number of waste packages in the repository) are mixed with larger volumes of water (e.g.,100,000 cubic meters of water or more). In each of these cases, the most restrictive MCL would be a projected dose of iodine-129 to the thyroid. That dose, in terms of tctal effective dose equivalent (TEDE), would be 0.1 mrem /yr, a small fraction of the dose limit of 25 mrem /yr TEDE in 10 CFR Part 63. NRC is not aware of any health and safety i
basis forlimiting annual dose to fractions of a millirem.
Markey/NMSS 09/9/99
(
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QUESTION 24.
(A)
How could the dispute between the EPA and the NRC over radiation standards be resolved other than by amending Superfund?
ANSWER.
Other alternatives include: (1) amending the Atomic Energy Act of 1954 to remove joint i
jurisdiction by NRC and EPA; (2) establishment of a Congressionally-mandated cleanup standard; (3) establishment of a generally applicable environmental standard by the EPA within its regulations with which NRC would be required to comply; and (4) recognition by the EPA that the NRC's regulation is protective of the public health and safety and the environment.
We beTieve that the EPA's commitment to its current regulatory approach differs so significantly from the NRC's support of fundamental radiation protection standards as described in national and intemational standards, that a Congressional resolution of these differences is desirable.
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r-l QUESTION 24.
(B)
Would the proposed amendments have broader implications for EPA's oversight of closed NRC-licensed facilities than just the radiation standards?
ANSWER.
No, the proposed amendments would not impact the EPA's oversight of non radiological
~
contaminants at NRC-licensed facilities. In fact, the NRC and the EPA have a generally successful working relationship at NRC-licensed facilities that are contaminated with mixed waste (i.e., waste that contains both hazardous waste subject to the Resource Conservation and Recovery Act and radinnrtive waste subject to the Atomic Energy Act) and in developing joint regulatory guidance for mixed waste. The proposed amendments will not impact this relationship.
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L QUESTION 25.
Why should neighbors of nuclear power plants not receive the same level
^
of protection' thet people who live near Superfund sites receive?
o ANSWER.
}'
i We believe that an equivalent level of potection is achicved after considering the methods used in applying the dose standard. NRC's 25 mrem /yr dose limit also includes a provision that.
the dose must be as low as is reasonably achievable (ALARA). This ALARA provision will generally achieve doses less than 25 mrem /yr. Actual doses will also be less than the 25 mrom/yr limit because of the conservatism built into dose modelling and resultant projections.
)
l Because of the uncertainties involved in such projection's, the models used by NRC use several layers of conservatism. The combined effect of NRC's ALARA requirement and the conservatism used in estimating dose for determining compliance, will generally result in actual doses significantly less than NRC's dose limit.
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The approach suggested by EPA results in the imposition of the CERCLA risk range (i.e.,104 4
4 to 10 ) on radionuclides.' The CERCLA guidance indicates that a risk level of 10 is a level of j
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protection that is not to be exceeded and that NRC's 25 mrem /yr dose criterion is not protective I
- because it would exceed that level.
l l-i NRC has reached the following conclusions regarding'tth risk range and its application:
l (1) EPA's derivation of 10 as a protective value appears to be a policyjudgement, and is 4
i inconsistent with intomational findings, (2) EPA inaccurately states that NRC's rule is not
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1 QUESTION 25. (Cont.)
protective, and (3) EPA inconsistently uses its protective value of 10. These conclusions are 4
discussed in the enclosure, j
e 8
~.
Enclosure:
Discussion of NRC Concems with EPA's CERCLA Guidance Contained in the December 12,1997 letter from Chairman Jackson to Carol Browner on Establishment of Cleanup Levels for CERCLA Sites with Radioactive Contamination -
e
Discussion of NRC Concerns with EPA's CERCLA Guidance
- 1. EPA's derivation of 10d as aprotective value appears to be a policy judgement, and is inconsistent with internadonal findings.
The CERCLA guidance indicates that a risk level of 10 is a level of protection that is not to be d
exceeded and that the 25 mremfyr dose criterion in NRC's final rule is not protective because it would exceed that level. A rationale for EPA's value of 10 can be found in a Federal Reaister d
notice (FRN) for EPA's "NationalEmission Standards for Hazardous Air Pollutants (NESHAPs)"
under the C'ean Air Act (54 FR 38044, September 14,1989). The FRN notes that in the Vinyl Chloride decision the EPA was directed to determine an accepiable risk level based on a judgement of what risks are " acceptable in the world in which we live". In response to the Vinyl Chloride decision [ Natural Resources Defense Council, Inc. v. EPA,824 F.2d at 1146 (D.C. Cir.
1987)], the FRN indicates that EPA compiled a review of societal risks to place risk estimates in perspective and to provide background and context for the EPA's judgement on acceptability of risks "in the world in which we live". The FRN states that individual risk of premature death in EPA's survey ranged from 104 to 10, and that the level of approximately 10 is within the 4
d range for ind;vidual risk in the survey and at a value that comports with many previous health risk decisions by EPA. The EPA risk value is applied in the CERCLA context [see 55 FR at 8715 (March 8,1990)].
The Intemational Commission on Radiation Protection (ICRP) and the National Council on Radiation Protection and Measurements (NCRP) use an approach similar to EPA's in setting an acceptable risk level. ICRP and NCRP are organizations which are chartered, and intemationally recognized, for the development of basic radiation protection standards. Their findings are contained in ICRP Publication 60 and in NCRP No.116, respectively. Based on their review of health and societalissues, both documents (while acknowledging the difficulty of setting standards for an " acceptable" public dose limit) arrive at 100 mrem /yr as a level that can be said to be acceptable. NCRP 116 notes that this value includes a review of risks of mortality faced by the public. The ICRP and NCRP approaches further reduce their 100 mrem /yr limit by the principle of " optimization," which includes considerations of constraints and cost-effectiveness.
Using the principles of setting of " individual dose and risk limits" and " optimization of protection" (noted above) and an additional margin to allow for the potential for exposure to more than one radiation source, the NRC issued a final rule on radiological criteria for license termination. The rule includes a dose criterion of 25 mrem /yr and further reduction based on ALARA (62 FR 39058, July 21,1997).
The EPA approach of setting an acceptable risk levelin the context of reviewing risks acceptable in society is similar to that followed by ICRP and NCRP, but, clearly, is no more scientifically credible than the ICRP or NCRP reports. The FRN on NESHAPs acknowledges that because of the uncertainties over health effects, EPA's decision will depend to a great extent on policyjudgement. Therefore, there is no reason to conclude that risk limits set through EPA's process are any more appropriate for protection than those set by ICRP and NCRP, nor is there a reason to conclude that NRC's rule is not protective.
Enclosure:
Question 25
2
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- 2. EPA inaccurately states that NRC's rule is not protective The CERCLA guidance does not address several items which will further lower the estimated risk from the implementation of NRChule. These items are inherent either in the NRC rule or in the characteristics of radioactive materials and include the following:
a) the requirement in the NRC r0le that doses be reduced below the rule's dose criterion through the ALARA ("as low as reasonably achievable"; defined in 10 CFR 20) process
' further lowers the risk for the large majority of NRC sites; b) radioactive decay of key contaminant nuclides which, for the large number of NRC facilities with contaminant nuclides with half-lives equal to 30 years or less, will result in reduction of the risk near or below that which EPA finds protective; and c) the uncertainties associated with estimating risks from radiation at such low dose levels.
Although NRC indicated in the FRN for its final rule (at 62 FR 39062) that it was not altering its policy regarding use of the linear non-threshold model as part of the j
rulemaking, the FRN also stated that there are uncertainties as to whether adverse radiation effects occur at all at the low levels of radiation being discussed. The actual i
risk from 25 mrem /yr is well within the boundaries of scientific uncertainty regarding the magnitude of the actual health effects at these low doses. Whether or not health effects result from a dose as small as 100 mrem is uncertain, as evidenced by the following statement of the Committee on the Biological Effects of ionizing radiation (BEIR V) in its 1990 report:
Studies of populations chronically exposed to low-level radiation, such as those residing in regions of elevated natural background radiation, have not shown consistent or conclusive evidence of an associated increase in risk of cancer.
This same point was made in a recent safety evabation report for National Aeronautics and Space Administration (NASA) Cassini mission (July 31,1997), that EPA participated in, which referenced a Health Physics Society position noting that, "below 10 rem the risk of health effects are either too small to be observed or are non-existent." Further, the Cassini report concluded that at the low individual dose rates expected that there is a high probability that there willbe no resultant latent cancers.
- 3. EPA inconsistently uses its protective value of 10d The CERCLA guidance states that the 25 mrem /yr dose criterion in NRC's rule results in an estimated lifetime risk of cancer incidence of 5x10 and that this is not protective compared to 4
4 10. On the other hand, the CERCLA guidance states that a 15 mrem /yr dose standard
'(estimated lifetime risk of cancerincidence of 3x10 ) h acceptable because "3x10d is 4
essentially equivalent to the presumptively safe level of 10 " (the CERCLA guidance cites to the 4
Clean Air Act rulemaking (54 FR 51677) as the basis for this equivalence).
Enclosure:
Question 25
o 3
The CERCI.A guidance statements are inconsistent and raise two specific issues. First, it is not apparent why one value would be considend unacceptable while the other is acceptable even d
- though both exceed the 10 risk level. Second, EPA uses cancer incidence to assess acceptability of the radiation dose levels compared to the 104 value, even though the FRN on NESHAPS (54 FR 38044) Indicates that the value of 10 was based on a survey which resulted d
in a range of lifetime risk of premature modality to be 10 to 10. Thus, the point of 4
comparison for assessing acceptability of the risk should be premature mortality. Further, it should be noted that the NCRP and ICRP use cancer mortality as the basis for their decisions.
If the risk coefficient for mortalityis used, the calculated estimate of lifetime risk from 25 d
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, mrom/yris 3.8x10 (based on a risk coefficient of 5x10 versus 7x10 for incidence), which
' approximates the 3x10 value that EPA concluded as essentially equivalent to the protective 4
value 104 l
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Enclosure:
Ouestion 25 s3 j
I-QUESTION 26.
In recommending elimination of the foreign ov;nership restrictions in the Atomic Energy Act, has the NRC obtained the concurrence of agencies l
responsible for defendqg the U.S. from national security threats, including the Department of Defense, the Joint Chiefs of Staff, the Director of Central 1ntag ence, and the Director of the Federal Bureau of g
4 Investigation? If not, why not? If so, please provide written copies of each agency's concurrence for the record.
ANSWER.
The Commission forwarded this legislative proposal, along with others that have now been Incorporated into H.R. 2531, to the Office of Management and Budget (OMB), which normally circulates such proposals among Executive Branch Agencies for the purpose of obtaining their views. OMB has informed us that it provided the NRC draft submission to several agencies, including the Department of Energy, the Ornartment of Defense, the Department of Justice, the Department of State and the National Security Council. According to OMB, none of these agencies objected to the proposal recomrne.1 ding elimination of the foreign ownership restriction.
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With respect to components of a Department, such as the Federal Bureau of Investigation (which is a component of the Department of Justice), we understand that OMB generally leaves it to the cognizant Department to determine which of its components should be consulted during the Departmental review of proposed legislation forwarded by OMB. In' addition, we understand that OMB does not customarily circulate proposals to the Central Intelligerice Agency.
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i QUESTION 26.'(Cont.)
' Any substantive or editorial comments received by OMB are provided to the agency proposing I
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the legislation. OMB does not provide the proposing agency (in this case, NRC) with copies of i
- written responsas of approval or to comment" that OMB has received.
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y, QUESTION 27.
if the foreign ownership restrictions of the Atomic Energy Act are repealed, on what basis would the NRC determine whether a particular i
foreign acquisition would be " inimical to the common defense and security," the standard under which you testified that such acquisitions would be reviewed?
ANSWER.
i if the proposed legislation were enacted, the Commisalon would consider a number of factors in making its common defense and security finding. Among the considerations would be the j
ove'rall state of relations between the United States and the foreign nation; the nonproliferation credentials of the applicant's nation and whether that nation supports international terrorism. If the Commission has any common defense and security concerns, the Commission would presumably consult with the Executive Branch before making its statutory findings on the j
application.
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l QUESTION 28.
If U.S. relations with the home country of a foreign owner of a U.S.
nuclear plant deteriorated following the acquisition, so that such
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i ownership now threatened the common defense and security, would the i
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NRC be able to revoke a license or order a divestiture?
)
ANSWER.
The Atomic Energy Act and the Commission's regulations do not permit foreign entities to directly own nuclear power plant facilities. To the extent that a foreign interest owns or controls to some degree a licensee, a negation action plan would have been in place to insulate any matters that might affect common defense and security frorr the foreign interest, even if the foreign interest was associated with a friendly nation. Thus, if U.S. relations with the respective nation of the. foreign interest deteriorated, the foreign ownership or control should not be able to have anyimpact on the common defense and security by reason of the negation action plan. In general, the NRC could revoke a license er take other regulatory action if at any time after the issuance of the license it determined that possession of the license would be inimical to the i
common defense and security.
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QUESTION 29.
If there was an accident at a nuclear plant and the U.S. subsidiary or
. affiliate of a foreign owner lacked substantial assets other than the plant itself, or failed to obtain sufficient insurance coverage, could we be sure that the victims would be atic to obtain damages from the assets of a foreign parent?
ANSWER.
The Price-Anderson Act does not contemplate victims needing to seek damages f om the assets of any licensee that has suffered a serious nuclear accident. The long-standing
. provisions and practices dealing with the damages that could be associated with an accident at
- a nuclear power plant are intended to assure that potentLI victims are adequately compensated irrespective of plant ownership.
Under the Atomic Energy Act, all commercial nuclear power plants require a licenso to operate; under the Price-Anderson Act a condition of that license,aquires that the plant be covered by the maximum commercialinsurance available. The NRC receives endorsements of the policies, and, therefore, has assurance that the maximum commercial insurance coverage is in effect.
The Price-Anderson Act further provides that every operating nuclear power plant participate in a pool with retrospective premium obligations. That is, the requirement to pay damages is not iniflated until there is an accident sufficiently large that it appears that the damages will exceed the amount of commercial insurance coverage. The industry pool covers all damages up to the e
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QUESTION 29. (Cont.)
Emit of liability for the nuclear incident. The value of the industry pool le now of the order of $9 bElon.
Only N damages were to excee6 t' e vri.ue of the industry pool would Congress be called upon to consider whether to compensate for additional damages and, if so, the amount and '.ne means.
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F.
p QUESTION 30.
Is it fair to ask the U.S. taxpayer under ' Price-Anderson insurance coverage to pick up the costs of a catastrophic nuclear accident l
caused by a foreign company operating on U.S. soll?
ANSWER.
insurance coverage under the Price-Anderson Act is not funded by U.S. taxpayers.
As explained in the response to Question 29, above, every operating nuclear power plant has obtained coverage to the maximum insurance coverage available. Additional coverage is provided under the Price-Andercon scheme; that coverage does not rely upon U.S. taxpayer funding for the payment of damages in the event of an accident at a nuclear power plant. Only if the damages exceed combined funds of the required maximum insurance coverage available and of the required nuclear power reactors' own required pool would Congress be called upon I
to consider how best to deal with that situation. Furthermore, it is notable that none of the funds available under the Price-Anderson scheme may cover damage to the nuclear power plant itself. The funds are entirely reserved for third party liability, that is, for those other than the licensees and their workers. (Workers receive compensation pursuant to Workmen's Compensation laws.)
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1 QUESTION 31.
(A)-
What do you anticipate the length of a combined construction and n
operating license would be (from the date the license was issued)
. under the NRC proposal?.
ANSWER.
- The length of a combined license would be 40 years, in accordance with Section 103.c of the Atomic Energy Act of 1954 (1954 Act).
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.The NRC has requested a legislative clarification to the 1954 Act to eliminate the uncertainty associated with the duration of operation under a combined license. The NRC's proposal is that the start of the 40-year period begins after completion of construction, when the Commissinn makes the finding required by 10 CFR 52.103(g). Since, under the older two-step licensing process, the operating license for a facility became effective immediately upon issuance of such a license, the duration of operation of the facility could be a full 40 years.
There is no reason why the potential duration of operations under a combined license should be less.
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FP QUESTION 31.
(B)
Would there be any upper bound on the total length of the license?.
ANSWER.
A combined license issued under 10 CFR Part 52 would be limited to 40 years, in accordance with Section 103.c of the Atomic Energy Act of 1954. The licensee could request a renewed operating license (not to exceed 20 years) under 10 CFR Part 54.
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r QUESTION 32.
I understand the proposal to eliminate NRC antitrust review is included in the President's electricity restructuring proposal. Wouldn't a comprehensive electricity restructuring bill that addressed broader market l
power concems be a more appropriate forum in which to consider this review?
i ANSWER.
NRC's antitrust proposal is contained in both the Administration's electricity restructuring bill (H.R.1828) and NRC's Authorization Bill for Fiscal Year 2000 (H.R. 2531). Enactment of the antitrust review elimination proposal through either of these bills would be welcomed by the Commission.
NRC's antitrust reviews are duplicative of other Federal agencies' efforts, and continuing this agency's efforts in this area is wasteful of its resources and contrary to the objective of streamlining government. Thus, even absent an electricity restructuring proposal, it would make sense for the NRC to go forward with a proposal to eliminate NRC antitrust reviews. For this reason, an NRC authorization bill is also an appropriate forum in which to consider a proposal to eliminate NRC antitrust reviews.
QUESTION 33.
(A)
Do you think that removing a requirement that hearings on uranium enrichment facilities be "on the record" will enhance publicconfidence in the NRC? If so, how?
ANSWER.
1 Removing the requirement that hearings on licensing of uranium enrichment facilities be "on the record" will provide the Commission with the same flexibility to determine the hearing procedures appropriate for such a hearing as the Commission already has with respect to other adjudicatory hearings regarding NRC licensing held under section 189 of the Atomic Energy Act. The Commission has the discretion to determine the degree of formality required in the
-latter proceedings, and is of the view that having such discretion is beneficial to the public.
Hearings that are required to be "on the record" must conform to the more elaborate formalities l
prescribed by the Administrative Procedure Act, and if not appropriately disciplined, can be inefficient, protracted, and costly to both the govemment and the parties to the proceedings.
The high cost, hngth, and formality of even well-disciplined proceedings can discourage public participation. We know of no other technical agency in the Federal government makes scientific and technical decisions in trial-type hearings. In fact, EPA, in its comments on our proposed standards for the nation high-level waste repository, recommended against formal proceedings, as did the DOE advisory committee that recommended in 1996 that DOE's self-regulation of its own nuclear facilities be replaced by external regulation. In fact, more and more Govemment agencies have been exercising greater flexibility in determining the i
appropriate hearing process in their adjudicatory proceedings on non-technical issues, in l
recognition of the fact that more streamlined and less formal proceedings can benefit the j
V QUESTION 33.(A)..
parties and the psblic, and help to conserve the resources of the agency holding the Proceedings and the parties to the proceedings. Striving for these goals should enhance public confidence in the NRC.
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QUESIlOM33.
(B)
After this restriction was removed, what legislative direction would
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remain on the form of hearings and on the recording of outside dews on the licensing?
ANSWER.
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If the restriction were removed, the following legislative directions would remain in the Atomic Energy Act with regard to hearings and the secording of outside views on the licensing of a
- uranium enrichment facility:
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- section 193 (b)(1) requires the Commission to conduct a single adjudicatory hearing with regard to the licensing of the construction and operation of a uranium enrichment facility under section 53 and 63 of the Act;
- section 193(b)(2) requires the hearing to be completed and a decision issued before the issuance of m Econse for that purpose;
- under section 189 a., in any proceeding under the Act for the granting of a license, the Commission must grant a hearing upon the request of any person whose interest may be affected by the proceeding, and must admit any such person as a party to the proceeding.
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- under section 189 b., the final decision in a hearing on the licensing of a uranium enrichment facility is subject to judicial review.
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OUESTION 34.
- (A)
Would receiving gifts from NRC licensees or their contractors or from associations that represent NRC licensees compromise the integrity of the NRC?
ANSWER.
I No. To address the issue raised by this question, the NRC's legislative proposal regarding gift acceptance (which has been incorporated into H.R. 2531) provides that the Commission must l
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. establish written criteria for determining whether to accept gifts, and that such criteria must take l
Into consideration whether the acceptance of a proffered gift would compromise the integrity of, or the appearance of the integrity of, the Nuclear Regulatory Commission or any officer or employee of the Commission. The purpose of this provision is to require tht, NRC to develop gift acceptance standards that will ensure that there will be no compromise -- and no appearance of compromise - of the integrity of the Commission or its employees.
It is noteworthy that a broad spectrum of Federal agencies, including independent regulatory agencies such as the NRC, have statutory gift acceptance authority. The Commission anticipates that this gift acceptance authority primarily would be used to accept technical l
publications and training equipment and materials.
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pe QUESTION 34.
(B)
If the NRC accepts gifts with restrictions, would those with money to give to the NRC be able to influence NRC priorities?
ANSWER.
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No. The Commission's policy is to maintain an arms-length relationship with its licensees,.
contractors, and others who might be motivated to seek influence over NRC priorities. This would be reflected in the gift acceptance criteria that the Commission would develop to implement the legislation.
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r-CONGRESSIONAL CORRESPONDENCE SYSTEM DOCUMENT PREPARATION CHECKLIST This check !!st is to be submitted with each document (or group of Os/As) sent for processing into the CCS.
1.
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