NUREG-0764, Forwards Draft Highlights of Public Comments Received on NUREG-0764, Toward Safety Goal:Discussion of Preliminary Policy Considerations

Forwards Draft Highlights of Public Comments Received on NUREG-0764, Toward Safety Goal:Discussion of Preliminary Policy Considerations

ML20009C929
Person / Time
Issue date:	07/14/1981
From:	Paul Goldberg NRC OFFICE OF POLICY EVALUATIONS (OPE)
To:	NRC OFFICE OF POLICY EVALUATIONS (OPE)
Shared Package
ML20009C927	List: NUREG-0764, Forwards Draft Highlights of Public Comments Received on NUREG-0764, Toward Safety Goal:Discussion of Preliminary Policy Considerations
References
FRN-45FR17023, RTR-NUREG-0764, RTR-NUREG-764, RULE-PR-50 NUDOCS 8107220155
Download: ML20009C929 (12)

Text

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l d,M' UNITE 9 STATES NUCLEAR REGULATORY COMMISSION o

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,I WASHINGTON, D. C. 20555 p$

July 14, 1981 MEMORANDUM FOR:

File FROM:

Paul Goldberg, Office of Policy Evaluation

SUBJECT:

HIGHLIGifG 0F -COMMENTS ON DEVELOPMENT OF A SAFETY G0AL

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The attached draft contains highlights of the 23 public comments on

' development of a safety goal.

It is an abridged version of a 61-page analysis which outlines the comments at some length.

Attachment:

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INTRODUCTION AND

SUMMARY

This paper' presents highlights of public comments received on NU'EG-0764, "Toward a safety Goal:

Discussion of Preliminary R

Policy Considerations", in response to the Commission's solicitation (46 FR 18827. March 26,1981).

4 Twenty-three comments on the Safety Goal Project have been received as of July.9.

The list of commenters and brief remarks characterizing their connents are presented in Table 1.

In the table, as well as in the text sections that follow, comments are addressed in the order in which they were received. Tabie 2 lists the topics covered by commenters. 'Some of these comments.are found only in the longer

' version of this analysis.

6

m-e TABLE '.

COMMENTS RECEIVED:

LIST AND

SUMMARY

k, 1.

Marvin Lewis believes that NRC is attempting to use a safety goal to provide a number of lives which may be traded for profit.

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No'rman Buske believ::s that the safety goal diverts attention from a W

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needed safety standard and that states should set their own standards.

3.

The Atomic Industrial Forum (AIF) responds to the questions listed

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.in NUREG-0764 and the Federal Register Notice and proffers its own

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proposed approach to safety goals.

h Robert klexander believes that one more Class 9 accident will eliminate

.4.

public~ acceptance of a nuclear program and that absence of strict

-verifiability dooms all quantitative goals.

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5.

Washington Public Power Supply System (WPPSS) is in general agreement 1

wit'n the AIF approach and believes that the technical bases for a 25 goal by which it could measure and demonstrate the high level of

'3j safety of its plants exi'st today.

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-6.

Kerr-McGee believes that two separate goals are needed for low d

probability, high risk events on the one hand and accidents or minor

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events in normal operations on the other.

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7. ' Albert Batcs considers the release of r'adiation to the environmant ki b.v any Federal agent or licensee a violation of the natural rights

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of citizens.

7 8.

Duke Power Company supports AIF's comments and proposal and believes that application of probabilistic risk techniques through use of f

quantitative safety criteria can assure an acceptable level of 7

safety.

9.

Cynthia Sharpe considers the safety goal a debate on the value of life versus the value of nuclear industry and technology.

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10.

Tennessee Valley Authority (TVA) believes that the ACRS proposal is 7

'a good starting point for discussion but that a goal should be simpler than the ACRS proposal.

11.

Stone & Webster (S&W) endorses the AIF proposal and believes that NRC'must establish a set of rules with a single quantitative, absolute 11 -

goal and should use the principles in WASH-1400 to analyze plant safety-related design features.

12.

The American Mining-Company endorses the concept of a safety goal I

but believes that NRC should consider the distinctions among the various elements of the fuel cycle in developing the goal.

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General Electric (GE endorses the AIF proposal and advocates establ'ishment of an interim safety goal representing an industry consensus.

14.

Northeast Utilities endorses the AIF proposal and believes that a goal is necessary-to prioritize and assess the plethora of proposed changes to plants and regulations.

15.

Bechtel endorses the AIF proposal.

16.

Dr. Henry Hurwitz states that the safety goal should avoid the hypocrisy of establishing radiological standards for nuclear reactors that are not being applied to energy efficient dwelling.

17.

The Union of Concerned Scientists (UCS) feels that a quantitative safety goal cannoc be a substitute for. conservative deterministic criteria for licensing.

18.

The New-York Public Interest Resear,ch Group (NYPIRG) expresses concern about the credibility of the NRC and other authorities and about NRC's treatment of public fears.

19.

Catherine Quigg believes that the ALARA (as low as reasonably achievable) app' roach to radiation exposure is unacceptable and that ALRAA (as low as achievable) would be a more socially responsible goal.

20.

Eckhard Festig believes that there should be a moratorium on reactor construction r snd unless a research program establishes that reactors witF jesirable characteristics can be built.

21.

Combustion Engineering endorses the AIF comments and proposal.

22.

Lynn Rudmin Chong suggests that the ALARA policy be discontinued and that the Union of Concerned Scientists and Physicians for Social Responsibility be included in NRC decisions to allay public fear and distrust.

23. Westinghouse endorses the AIF -proposal.

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3 TABLE 2 TOPICS COVERED BY COMMENTERS Critique.of NRC AIF Report Questions Other Comenter Proposal Schedule (NUREG-9764) 1

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3 4

5 6 7 Comments Marvin Lewis

'X X

X Norman Baske X

AIF.

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X X

X X

X X X X X

Robert Alexander S&W X

X X

X X

X X X WPPSS X

X X

X X

X X X Kerr-McGee X

Albert Bates, PLENTY X

Duke X

X X

Cynthia Sharpe TVA X

X X

X X

X X X X PSE&G MC X

X GE X

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NU X

X X

X X

X X X Bechtel X

X X

Dr. Ilenry liprwitz UCS X

X NY PIRG X

X X

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X X X Catherine Quigg X

Eckhard Festag X

Combustion Engineering X

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Lynn Rudmin Chong X

Westinghouse X

X X

• The AIF proposal is the only detailed proposal received in response to the Commission's solicitation.

X's in this column opposite other commentersindicate references to the AIF proposal.

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II. AIF PROPOSED APPROACH The most extens'ive coments are those of the Atomic Industrial Forum (AIF), which commented on NUREG'-0764 and also offered "A Proposed Approach to the Establishment and Use of Quantitative Safety Goals in the Nuclear Regulatory Process." Because this is a detailed proposal which has been endorsed by eight of the other comenters -- Stone and Webster (S&W), Duke Power (Duke), Washington Public Power Supply System (WPPSS), General Electric (GE), Northeast Utilities (NU), Bechtel Power Corporation (Bechtel), Combustion Engineering (CE), and Westinghouse Eiectric Corporation -- AIF's approach is outlined here.

AIF suggests three governing principles to provide a rational and logical framework upon which specific quantitative safety goals can be founded:

1.

The goals should provide a level of protection for members of the public such that no individual bears an inordinate risk.

2.

The quantitative safety goals for nuclear power plants should be consistent with those applied to other technologies. The goals should endeavor to ensure that incremental societal risks are cor:nensurate with the societal benefits derived from the technology.

3.

The goals should promote the rational allocation of societal resources for the purposes of reducing public risk in order to achieve the optimum benefit attainable for the cost.

3 II-2 In accord with these principles, AIF proposes twa primary criteria and two secondary criteria each of which has an associated quantitative goal which satisfies the criterion in AIF's view. The primary criteria establish goals for limit,ing radiological health risks to individuals and to society at large. The secondary criteria relate to allocation of resources in achieving marginal reductions in residual risk and in providing goals for the prevention of accidents which could pose risk.

The primary criteria and associated goals are:

INDIVIDUAL RISK CRITERION Th'e maximum incremental risk of radiolo5ically induced adverse health effects to a hypothetical biolog' ally average individual in the vicinity of a nuclear plant site should not result in a significant increasa in the individual's annual mortality risk.

Suggested Safety Goal:

Less 'than 10-5 per year mortality risk to maximum exposed average individual.

POPULATION RISK CRITERION The incremental cumulative risk of adverse radio?ogically induced health effects to the exposed population per 1000 MW(e) of nuclear power capacity, considering the annual frequency and consequences 6

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Suggested Safety Goal:

Less than 1 Statistically estimated fatality /yr per 1000 MW(e)

The secondary criteria and associated goals are:

COST-BENEFIT CRITERION Neasures proposed to achieve incremental reductions in residual risk beyond those provided to meet the prinary criteria should be evaluated on a cost-benefit basis. The benefit, in terms of population risk reduction, afforded by a change in plant design or operating procedure should be comparable to that which is generally achievable through alternative investment of the cost of the change l

in other =reas of public risk recaction.

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Suggested Goal:

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$100/ man-rem (equivalent to $1 million per statistically estimated lifesaved).

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III. SCRIDULE OF SAFETY GOAL DEVELOPMEtlT AND SEQUENCE OF OTHER NRC ACTIVITIES i

i Most of the commenters had some view on the NRC schedule for development of a safety goal and the need for a goal to be available in time to influence other NRC activities. Marvin Lewis considers the period for coment on NUREG-0754 inadequate.

Ten industry comenters state that a.sa.fety goal should be developed

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promptly; eight of the ten also believe that it should precede and guide other NRC rulemakings, especicily the degraded core rulemcking.

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c-IV. CRITIQUE OF NRC REPORT (NUREG-0764)

Nine connenters take the vit v that NUREG-0764 leaves out considerations important to developing a safety goal cr that an acceptable safety goal cannot be developed.

p One of them. Robert Alexander, believes that "one more Class 9 b

accident" will eliminate public acceptance of a nuclear program and that absence of strict verifiability dooms all quantitative goals.

Cynthia Sharpe finds the notion that'it is possible to develop a -

• safety goal" frightening because " numerous studies have shown that there is no safe exposure to radiation" and she considers the development of a safety goal a debate on the vclue of life versus the value of auclear industry and technology.

According to Marvin Lewis, the proper objective of a safety goal is to.save lives and justify turning off all nuclear power plants; the improper use is to provide a number of lives which may be traded for profit. He feels that this latter use is what NRC is attempting to do.

UCS believes that in order for a safety goal to be a useful tool for regulating nuclear power, it must meet the following conditions:

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IV-2 1.

Compliance with the goal must be technically verifiable within reasonably small uncertainty limits. Stating the uncertainty, however clearly, is not a substitute for reducing it to acceptable levels when regulatory decisions are to be based upon quantitative assessment.

2.

Establishment and implementation of the goal must fairly account for the unique risks of catastrophic nuclear accidents, including economic costs.

3.

Establishment and implementation of the goal must not require NRC to resolve questions which are political in nature.

4.

The scientific and technical community outside the nuclear industry and HRC must be involved in establishing the goal and reviewing risk assessments.

UCS is, unhappily, confident that risk assessment is destined to be an adversary tool for the nuclear industry to resist safety improvements rather than as a means to build consensus around a safety goal.

5.

Both the safety goal and the quantitative risk assessments

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must be understood and accepted by the public as being unbiased 1

and technically justified.

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Because of the inherent uncertainties of quantitative risk assessment a quantitative safety goal cannot be a substitute for conservative deterministic criteria in the licensing of l

nuclear plants.

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NYPIRG suggests that gamma r/diation may be more carcinogenic than had biien assumed and that health effects calculations may be subject to. revision.

NYPIRG also expresses concern about the credibility of WRC and other authorities and about NRC's treatment of public fears of radiation.

Cathe~rine Quigg recommends that the ALARA (as icw as reasonably achieveble) policy.for radiation exposure be replaced by an ALAA (as low as achievable) goal.

Eckhard Festag belives that there should be a moratorium on reactor construction unless and until a research program est?blishes that reactors with more desirable characteristics can be built.

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Lynn Chong suggests that the ALARA policy be discontinued and that the Union of Concerned Scientists and Physicians for Social Responsibility be' included in NRC decisions.

Albert Bates considers the release of radiation /b3 the environment ik

• a violation of the natural rights of citizens, to which it is beyond our capability to assign a cost.

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