ML25195A216

12-11-79 Comments on the Pause in Licensing

ML25195A216
Person / Time
Issue date:	12/11/1979
From:	Carbon M Advisory Committee on Reactor Safeguards
To:	Ahearne J NRC/Chairman
References
Download: ML25195A216 (1)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS WASHINGTON, D. C. 20555 Dr. John F. Ahearne Chairman December 11, 1979

u. s. Nuclear Regulatory Commission Washington, DC 20555

Subject:

CD1MENTS 00 THE PAUSE IN LICENSI?I;

Dear Dr. Ahearne:

The President's Commission on the Accident at Three Mile Island has recommended that:

• Because safety measures to afford better protection for the affected population can be drawn from the high standards for plant safety recommended in this report, the NRC or its suc-cessor should, on a case-by-case basis, before issuing a new construction permit or operating license:

(a) assess the need to introduce new safety improvements recommended in this report and in NRC and industry studies; (b) review, considering the recomnendations set forth in this report, the competency of the prospective operating licensee to manage the plant and the adequacy of its training program for operating personnel; and (c) condition licensing upon review and approval of the state and local emergency plans*.

Since issuance of this report, the Nuclear Regulatory Commission has stated that there will be a pause of many months before the NRC will li-cense any of the reactors now nearing readiness for operation while safety improvements are worked out for the reactors already in operation. Longer delays are anticipated for new construction permits.

The ACRS agrees with most of the recommendations made by the President's Commission.

The ACRS supports the basic recommendation of the President's Commission which is quoted above, but with some qualifications which are discussed below.

The Ams believes that the risk to the public health and safety which is posed by the operating nuclear power plants is comparable to or probably smaller than the risk posed by other existing methods of generating the same quantity of electricity. The Ams also believes that this risk is comparable to or less than that posed by many other technological activi-ties of society.

2821

Dr. John F. Ahearne 2 -

December 11, 1979 The ACRS has, in the past and again since the Three Mile Island accident, reconmended that the NRC and the nuclear industry take major steps to*

prove the safety of nuclear power reactors. The ACRS believes that it is proper that nuclear power be safer than other comparable technologies.

The Conmittee has sought this goal. It believes that the COlB'ltry wants a higher level of safety for nuclear reactors and is willing to pay for it.

The ACRS also believes that the COlB'ltry wants a higher degree of assurance as to the level of safety which is being attained.

While the ACRS believes that interim licensing of the next six to twelve nuclear power reactors for operation on the same basis as is now being accepted for currently operating reactors would not pose lmdue risk to the public health and safety, the ACRS favors the consideration of additional improvements in their safety on a case-by-case basis, as reconmended by the President's Conmission. Nevertheless, the following additional considera-tions can and should have a strong bearing on the specific NRC approach and actions in this regard:

1)

For those reactors which are ready for power operation, there exists the possibility that a considerable body of experimental information having either a plant-specific or a general safety significance can be ob-tained by performing appropriate tests on systems or the entire plant at powers up to about 51 of full power. These are tests which are not usually run because of the time they consume. They would afford essentially no risk to the p.tblic health and safety. There also exists the possibility of providing mre than the normal training of operators.

2) If the NRC pause becomes relatively extended, there may arise a more severe national need for additional electric power. The ACHS recom-mends that consideration be given to permitting newly completed nuclear power plants which meet the requirements of NtJRm-0578 to start up and undergo testing at power levels up to 501 or 751 of full power, after which they could be placed in a shutdown condition, available for call in the event of national need, while the NRC reaches a resolution as to the addi-tional safety requirements it will impose before permitting normal oonmer-cial operation.

3)

The ACRS believes that the safety improvements reconmended by the President's Conmission, the various NRC Task Forces and the ACRS itself, should be evaluated and acted upon expeditiously. However, the ACRS believes that a judicious choice is required as to which reconmendations require implementation promptly, which require implementation on a speci-fied time scale during which reactors are permitted to operate, and which warrant study and resolution on some specified and achievable time scale.

The ACRS supports the rapid steps being taken by the NRC to develop an action plan and will expedite its review of the plan.

2822

Dr. John F. Aheame 3 -

December 11, 1979

4. Although the ACRS believes that operating reactors should receive priority, and that reactors under construction also require emphasis from the NRC Staff, the Conmittee reconmends that the NRC Staff take steps in timely fashion to redirect, as appropriate, the design of reactors for which a construction permit has not been granted or for which construction has not been initiated. General guidance, as well as requests for studies of design alternatives could be useful in this regard. 'lbe Conmittee be-lieves that the initiation of possible design changes need not await the complete developnent of a final NRC position on changed or additional re-quirements for reactors which have not yet received a construction permit.

The ACRS is available to work with the NRC Staff to help achieve these actions.

2823 Max w. carbon Oiaimen