ML20134F678

Expresses Appreciation for Visit of a Drozd in Sept.Policy Statement, Safety Goals for Operation of Npps, Issued by NRC in 1986 Encl

ML20134F678
Person / Time
Issue date:	01/30/1997
From:	Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM)
To:	Ming W AFFILIATION NOT ASSIGNED
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ML20134F679	List: ML20134F678 ML20134F693
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NUDOCS 9702100094
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b UNITED STATES 1

e- t NUCLEAR RE!3ULATORY COMMISSION WASHINGTON, D.C. 20555 0001

/ January 30, 1997 CHAIRMAN J

i Mr. Wu Jian Ming Vice-Chairman Science & Technology Committee Shanghai Nuclear Engineering Research and Design Institute i P.O. Box 7633

Shanghai 200233 China

)

Dear Mr. Wu:

Thank you for your recent letter expressing appreciation for the visit of l Mr. Andrzej Drozd in September. I am pleased that y:u and other members of  !

' your I'.;titute found his brietings on source term calculatic s and fission 4

product transport under post accident conditions to be informative and useful.

Post-accident containment analysis is a complex task involving licensing

. requirements, design-basis criteria, and severe accident considerations.

In your letter, you ask for assistance in establishing safety goals for l nuclear power plants. Since the early 1970s, the Nuclear Regulatory Commission (NRC) has devoted significant effort towards developing probabilistic risk assessment (PRA) methodology. These techniques provide a structured way to assess the likelihood and consequences of severe accidents  !

. - at nuclear power plants. As the insights and results from a number of plant-specific PRA studies became available in the 1980s, this Agency believed it would be appropriate to establish expectations and goals relating to public risk contributions. These goals were not intended to be specific safety criteria for nuclear plants, but rather to identify acceptable public risk l contribution for the overall population from U.S. commercial nuclear plants. '

4 Consequently, in 1986, the NRC issued a policy statement, " Safety Goals for the Operation of Nuclear Power Plants." A copy of this policy statement is 1 enclosed.

The objective of this policy statement was to establish goals that broadly defined an acceptable level of radiological risk to the public, for which nuclear power plant operations should not be a significant contributor to a i person's risk of accidental death or injury These goals also assisted us in considering the necessity and benefits of proposed regulatory changes as they related to groups of plants.

The qualitative safety goals were stated as follows: //

4 Individual members of the public should be provided a level of protection from the consequences of nuclear power plant v

[

operation such that individuals bear no significant

additional risk to life and health.

9702100094 970i30 pL k[j)./0yM k PDR COMMS NRCC 7 CORRESPONDENCE PDR

Societal risks to life and health from nuclear power plant operation should be comparable to or less than the risks of generating electricity by viable competing technologies and should not be a significant addition to other societal risks.

l The following quantitative health objectives are to be used in determining  ;

achievement of the qualitative goals:

The risk to an average individual in the vicinity of a nuclear power plant of prompt fatalities that might result from reactor accidents should not exceed one-tenth of one i percent (0.1 percent) of the sum of prompt fatality risks resulting from other accidents to which members of the U.S. l population are generally exposed.

The risk to the population in the area near a nuclear power i plant of cancer fatalities that might result from nuclear power plant operation should not exceed one-tenth of one percent (0.1 percent) of the sum of cancer fatality risks l resulting from all other causes.

You may find the above public risk objectives helpful in developing safety goals for your nuclear plants. While such an approach does ensure that the relative risk contribution from nuclear power is very small compared to other

. societal risks, it does require relatively complete severe accident evaluations to be completed, which include dose and consequence assessments for either a surrogate site or some group of individual reactor sites.

At the time the Safety Goal was being developed, the NRC also considered goals related to other measures of risk that did not require completion of a full Level 3 PRA, which requires an assessment of risk to the public. In addition to the quantitative health objectives defined above,4the Commission identified a subsidiary objective for core damage frequency (10 / reactor-year) to ensure that a severe reactor accident would be unlikely at any operating reactor.

Additionally, a subsidiary objective for large early radioactive material release frequency (104 / reactor-year) was suggested as a possible criterion to ensure that adequate defense-in-depth and accident mitigation capabilities were maintained. Since comparisons of core damage and large early release frequencies to these subsidiary guidelines are more directly determined than public dose and impacts, they provide useful insights when assessing proposed regulatory actions.

As stated above, these goals, quantitative health objectives and subsidiary objectives were not initially intended for plant-specific decisions. Rather, they were utilized to assess the generic impacts of proposed regulatory action. The NRC continues to increase the use of probabilistic risk assessment in its regulatory processes. At this time, the Commission is considering whether safety goal subsidiary objectives should be applied to plant-specific safety decisions.

It is expected that draft regulatory guidance documents proposing the use of plant-specific decision criteria will be issued for public comment in early 1997. These documents will focus upon what risk and safety criteria should be applied when considering modifications to a plant's licensing basis. You may find the draft guidance to be of interest and the staff will make such documents available to you when they are issued.

Considerable activities related to risk informed decision making are also ongoing at such organizations as the Nuclear Energy Agency (NEA) and International Atomic Energy Agency (IAEA). You may find their work useful in your safety goal activities.

If we can be of further help in this area, please contact our Office of International Programs.

Sincerely, k J _.

Shirley Ann Jackson )

Enclosure:

Safety Goal Policy Statement i l

I l

W .

30028 Fed:rcl R:gister / Vol. 51 No.162 / Thursday. August 21,1986 / Rules and Regulations NUCl. EAR REGULATORY 7. On page 28048. In the first column. Acnow: Policy statement.

COMMISSION in the fourth paragraph under the C heading, in the 7th line, the word suestsann This policy statement focuses 10 CFR Part 50 " exceed" should read " exceeds", on the risks to the public from nuclear

a. On page 28046,in the third column. Power plant operation. its objective is to Safety Goals for the Operation of in the second complete paragraph, in the establish goals that broadly define an Ndear Power Planta; PoHey toth line, the word "estmates" should acceptable level of radiological risk. In Statement; Co.-Gr. and read " estimates". developing the policy statement, the J Reputscetion NRC sponsored two public workshops l

9. On page 28047. In the first column. d p , '

Aeasect Nuclear Regulatory in the second paragraph under V. in the I ur p i e sd Commission. 2nd ime the word " goal, should read 1982, conducted a 2. year evaluation Acnosc Policy statement: correction and goals . during 1983 to 1985, and received the I republication. 10. On page 28047, in the first column. views of its Advisory Committee on in the second paragraph under V. in the Reactor Safeguards.

susssaann This document corrects a 18th line, the word "guidence" should number of typographical errors found m, %e Commission has established Iwo read " guidance". qualitative safety goals which are a a as pu s in

11. On page 28047. in the second supported by two quantitative 9 ,

c lumn. in the 1st line, the word (51 FR 28044). %e policy statement ob ectives.These two supporting

" Sitting" should read " Siting", and in the ob,ectives are based on the principle M ',I *

, t at broad $y define an acceptable level of radiological risk with 2nd line, the word "in" should read "is". that nuclear risks should not be a

12. On page 28047, in the third column. s,ignificant addition to other societal under General Perfonnance Guideline, noks ne Commission wants to make

~ regard to the operauon ot nuclear power in the 2nd line. the phrase "to a low" clear that no death attributable to plants. In addition, the policy statement should read "to an as low". nuclear power plant operation will ever la being republished in its entirety in 11 On page 28048, in the second be " acceptable" in the sense that the order to highlight the key elements of the policy statement. column. in the second rargraph under C:mmission would tegard it as a, routine Commissioner Bernthara separate or permissible event. The Commission is ron FURTHER INFontsADON CONTACT. discussing acceptable nsks not Merrill Taylor, Regional Operations and views. In the 4tl2 line, place the word "does" between the words "it" and acceptable deaths.

Generic Requirements Staff. Office of # ## " " "

the F.xecutive Director for Operations. "#' *

• F #

14. On page 28048, in the second follows:

U.S. Nuclear Regulatory Commission.

Washington, DC 20555. Telepho m :501- column. in the last paragraph of the -Individus! members of the public g 492-4356.

column. on the 7th line, the word should be provided a level of in FR Doc. 86-17496. published in the " options" should read " option". protection from the consequences of

, FederalRegister of Monday. AugaM 4. 15. On page 28048, in the third column. nuclear power plant operation such 1986. make the followmg corrections: in the 2ndline, the term " defense-in- that individuals bear no significant

..' 1. On page 2a044, in the first column. dept" shotfld read," defense.m-depth", additional risk to life and health.

In the Summary statement,in the 12th Dated si Bethesda. Maryland. this 14th day -Societal risks to life and health from line. the word " Commission" should of August.tae6. nuclear power plant operation should For the Nuc! car Regulatory Comsnission. be comparable to or less than the

2. On page 28044. In the third column. risks of generating electricity by in the 6th hne, the word "on should l*h" PhiliP*'

viable competing technoIogies and read "of". end in the 11th lme following Chiel. Aules cadhocedures Branct. Divisio, , ,

of/ths ennecoMs. Office of should not be a significant addition to the word "everything" add the word "tha t". Adnutueuction. Other societal risks.

3. On page 28045. In the heading of the IFR Doc. as-tant Fded s-2us, a 4s sm) . The following quantitative first column. the word "This" should sa m a coorrese4s objectives are to be used in determining read "this". echievement of the above safety goals:

4. On page 28045. in the second -The risk to an average individualin column. in the second complete 10 CFR Part 50 the vicinity of a nuclear power plant paragraph. in the 13th line, the word of prompt fatalities that might result

" goals" should read " goal". Safety Goals for the Operations of from reactor accidents should not exceed one. tenth of one percent (0.1

5. On page 28045, in the second Nuclear Power Plants; Policy column, the last word at the bottom of Statement; Repubscetion percent) of the sum of prompt fatality nsks resulting from other accidents to th C I.urnn.p1 ants" should read [ Editorial Note-The following document which members of the U.S. population "p -

was originally published at pase 28044 in are generall exposed.

6. On page 28045,in the third column, the issue of Monday. August 4.1 sees it is --The risk to e population in the area in the third complete paragraph. in the being republished in its entuety, wtih near a nuclear power plant of cancer 4th line, the last word "have" 6hould conections, at the request of the agency l fatalities that might result from read "has", and in the tith line, the AotNew Nuclear Regulatory nuclear power plant operation should word "need" should read "needed". Commission. not exceed one-tenth of one percent

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l t I r

Federal Register / Vel 51, No.162 / Thursd3y, August 21, 1986 / Rules and Regulations 30029

(0.1 percent) of the sum of cancer fatahty risks resulting from all other determined to be quite small.They will

. continue to receive careful B. Development of this Stotement of

causes. Safety Pblicy considerstion. The possible effects of IIPescTsvt oATE

August 4,1986. sabotage or diversion of nuclear pon surrwen sospeassaTeoes coerra,cT:

in developing the policy statement.

material are also' not presently included Merri'l Tsylor, Regional Operations and in the safety goals. At pmaent there is the Commission sohcited and benefited Generic Requiressants Staff. Office of from the information and suggestions no basis on which to provide a measure provided by workshop discussions.

the Executive Director for Opere tions, of risk on these motien. It is the NRC-sponsored workshops were held in U.S. Nuclear Regulatory Commiwlon, Commission's intention that everything Palo Alto, California,on April 1-3,1981 Washington, DC 20555. Telephone (301/ that is needed will be done to keep 482 4356). these types of risks at their presentJuly very and in Harpers Ferry, West Virgin 23-24.1981.The first workshop

, low level; and it is the Commission's addressed general issues involved in foUowing pmeento the Commission a ** Pac 88 tion that eNorts on this point developing safety goals.ne second Pohey Staten t on Se y Goals wul continue to be a-aful With workshop focused on a discussion paper O c ar wer these exceptions,it is the Commission's pg pers on o intent that the risks from all the various which presented Iroposed safety goals.

Both workshope Ieatured discussions initiating a+-R' _z be taken into L letroduction among knowledgeable persons drawn account to the best of the capability of arrent evaluation techniques. from industry, public interest groups, A. AirposeondScope universities, and elsewhere, who in its response to the la the evaluation of nuclear power represented a broad range of recosranendations of the President's plant operation, the staff considers perspective: and disciplines.

Commission on the Accident at Th ee Sever #I types of releases. Current NRC practice addresses the riska to the ne NRC Office of Policy Evaluation Mile Island, the Nuclear Regulatory pubhc resulting from operating nuclear submitted to the Commission forits Commission (NRC) stated that it was consideration a Discussion Paper on

' " prepared to move forward with an power plants. Before a nuclear power Safety Goals for Nuclear Power Plants explicit pohey statement on safety plant is licensed to operate. NRC r in November 1981 and a revised safety :

philosophy and the role of safety-cost prepares an environmentalimpact goal report in July 1982.

l tradeoffs in the NRC safety decisions." Md

his policy statement is the result. 8Qent

, , o the redi ca! impacts of The Commission also took into Current regulatory practices are routine operation of the plant and consideration the comments and

- believed to ensure that the basic accidents on the population in the region suggestions received from the pubh,c m, ,

' around the plant site.ne assessment response to the proposed Pohey statutory re)uirement.

pmtection o the public,is met. adequate d Statement on " Safety Coals for Nuclear l

,""g,'j;Qp bli eom g nd m be g Nevertheless, current practices could be e, 9 Power plants." pubbshed on February g improved to provide a better means for hearinge. For all plants licensed to 17,1m (47 FR 7023). FoHowing pubhc g testing the adequacy of and need for operate, NRC has found that there will comment, a revised Policy Statement current and proposed regulatory be no measurable radiologicalirnpact on was issued on March 14,1963 (48 FR requirements. He Commission believes any member of the public from routine 10772) and a 2-year evaluation period

• opera tion of the plant. (

Reference:

NRC began.

I"M'n'd et 8ulat on staff calculations of radiciogicalimpact ne Commission used the staff report

.; oy nuc3 ear power pgants, a more on humans contained in Final Environmental Statements for specific and its recommendations that resulted predictable regulatory process, a pubh.c from the 2-year evaluation of safety understanding of the regulatory criteria nuclear power plants; e.g. NUREG-0779,

. NURECA812, and NUREG-0854.) goals in developing this final Policy that the NRC applies, and pubhc Statement. Additionally,the t

confidence in the safety of operating ne objective of the Commission's Commi sion had benefit of further plants.nis staternent of NRC safety policy statement is to establish goals comments from its Advisory Committee ,

policy expresses the Commission's that broadly define an acceptable level on Reactor Safeguards (ACRS) and by views on the level of risks to public of radiological risk that might be senior NRC management.

-J health and safety that the industry imposed on the public as a result of should strive for in its nuclear power . Based on the results of this plants. nuclear power plant operation. While mformation, the Commission has this policy statement includes the risks determined that the qualitative safety his policy statement focuses on the of normal operation, as well as goals will remain unchanged from its risks to the public from nuclear power accidents, the Commission believes that March 1983 revised policy statement, plant operation.nese are the risks from because of compliance with Federal and the Commission adopts these as its release of radioactive mater'als from the Radiation Council (FRC) guidance, (40 safety goals for the operation of nuclear reactor to the environment from normal CFR Part 190), and NRC's regulations (10 power plants.

operations as well as from accidents. CFR Part 20 and Appendix ! to Part 50).

He Commission will refer to these risks the risks from routine emissions are II. Qualitative Safety Goals as the risks of nuclear power ; lant small compared to the safety goals.

operation. The risks from the nuclear The Commission has decided to adopt fuel cycle are not included in the safety nerefore, the Commission believes that qualitative safety goals that are goals. these risks need not be routinely supported by quantitative health effects analyzed on a case by case basis in These fuel cycle risks have been objectives for use in the regulatory considered in their own right and order to demonstrate conformar ce with decisionmaking process. The the safety goals.

Commission's first qualitative safety c> .-

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30030 Federal Regi ter / Vol. 5L No.162 / Thursday. August 2L 1986 / Rules and Re,gulationn __

I goalis that the risk hum nuclear power core damage accident will not occur at a acceptable risks. not acceptable deaths.

plant operation should not be a U.S. nuclear power plant. In any fatal accident.a course of significant contributor to a person's risk conduct posing an acceptable risk at one i of accidentaldeath orJnjury.Heintent IIL Quantitative Ob}ec6ves Used To moment results in an unacceptable is to require such a level of safety that U*"8* ^C * * **' ' O ' 8'I*'I

• death mcments later.This is true individusis living orworking near A. GenemlConsidemtions whether one speaks of driving.

nuclear power plants should be able t swimining. Dying or genuating he quantitativebeattli effects electricity from coal.Eachof these so about their daily lives without,special objectives establish NRC guldance for scuvities poses a calculable risk to concern by virtue of their proximity t pubhc protection which nuclearplant these planta.hs, the Comunission's sodety and to individuals.Some of l designers and operators should strive to those who accept the risk (or are part of O"' **I*'Y 8**I I*- achieve A key element in formulating a a society that accepts risk) do not Individualmemben ofthepublic qualitative safetysoal whose should be providado derelefpmsection achievement is measured by survin We intend est no such l accidents willoccur, but the possibility fran the mnseguances safmudeerpower quanotative bealth effects objectives is cannotbe enurdy chminated.

plant opemtion such Jhat indiridaals to understand both the strengths and bearno sq'rnifiant"Wrisk to Jif* hmlutions of b techniques by which Furthermore. Individual and socletal risks from nuclear power plants are andheal A %dges whede guahtatin Even though protectionefindividust generally estimated to be considerably safety goal has been met. less dan th risk eat society is now members of the public inherently A major step forwardin the provides substantf ai societal protection, development and 4 atof acddent exposed to from each of the other the Commission alsodecided that a kmit risk quantification was takeninthe activities mentioned above.

should be placed on the societalrisks ReactorSafety StudyMASH-MOD) C Health Effects-Pmmpt andLotent posed by nuclear power plantoperation. completed in tera.Nobjective of the CancerNoriality /tlaks ne Commission also believes that the Study was "to try to reach some ne Commission has decided to adopt risks of nuclear power plant operation meaningful conclusions about the aiskof & Mlowing two health effects as 6e ,

should be comparable to or less than the nuclear socidents." & Study did not quanmauve objectives conceming risks from other viable means of directly address the question of what mortality n,sks to be used in determ,imng generating the same quanttty of level of risk from nuclear socidents was achievement of the quaittative safety electrical energy. ms.the l acceptaWe. g als- i Commission's second safety goat is- S nce the completion of the Reactor

• The risk to an avemse individualm, Societalrisks to hfe andheotth from Safety Study, further progress in the vicinity of onuclearpowerplant of g nuclectpowerpfant operation should be developing probabIlistic risk a esesement pmmptfatalities that might resultfmm compamble to orless than due risks of and la occumulating re1evant data has generating electricity by a?iable led to a recognition thatit is fearMe to reactor accidents shouldnot exceed competing technologies and should not one tenth of one percent (0.t, percent) of begin to use quantitative safety the sum ofpmmptfotclity risks be a significant addition to other objectives ior timited purposes.

However, becanse of the sktable resultingfmm otheraccidents to which societalrisks.

i ne broad spectrum of expert opinion uncertainties stillpresent in the mefhods members of the U.S.popufation are .

I on the risks posed by electrical and the gaps in the data bese-essen6al genemTly exposed  ;

generation by coaland the absence of elements needed togauge whether the

• b risk to the population in the authoritative data make it impractical to objectives have been schleved-dre crea near a nuclearpowerplant of calibrate nuclear safety goals by quantitative objectives shouldbe concerfatalities that might resultfrom comparing them with coalriska based viewed es alming points or numerical nucfearpowerplant opemtion should on what we know today. Howevet. the not exceed one-tenth of one percent (O.t benchmarksof performance. In Commission has established the particular, because of the present percentf of the sum ofcancerfatality risks resulting fmm all other causes.

quantitative health effects objectives in limitations in b state of the art af such a way that nuclearrisks are not a quantitatively a=H-Hn= cisks, the ne Commission believes bt his significant addition to othersecaetal ratio of 0.1 percent appsopriately reflects quantitative heshh effects objectives are both of the qualitativegoals-to provide not a substitute for axisting segulations.

riska.

ne Commission recognizes the that individuals and societybear no Severe core damage accidents can lead to more serious accidents with the importance of mitigating the significant additional risk. However, this consequences of a core-melt accident does not necessarily mean that an potential for life-thseatening offsite additional risk that exceeds 0.1 percent release of radiation,for evacuation of and continues to emphasize features members of the public, and for such as contalament,alting in less would by itself constitute a signIricant antamination of public property. Apart populated areaa.andemergency additionst risk.De 0.1 percent refio to from their heal 0 and safety planning as integral parts of the defense. other risks is low enough to su) port an consequences, severe core damage in<lepth concept associated withits expectaGon that people living or accidents can erode public conGdence la accident prevention and mitigation working near nuclear power plants the safety of nuclear power and can lead philosophy. would have no special concern due to to furtherinstabihty and the plant's proximity.

unpredictability for the industry. In R4uoneofin M Mfectins The average Individual in the vicinity order to avoid these adverse De Commission wants to make clear of the plant is dermed as the average consequences, the Commission intends at the beginning of this section that no individual biologically (in terms of age to continue to pursue a regu$atory death attributable to nuclear power and other risk factors) and locationally plant operation will ever be who resides within a mile from the plant program that has as its ob}ective providing reasonable assurance, while " acceptable" in the sense that the site boundary.This means that the giving appropriate consideration to the Commission would regard it as a routine average individualis found by uncertainties involved, that a severe or permissible event. We are discussing accumulating the estimated individual l'

i i

l Focieral Register / Vol. 51. No.182 / "Ihursday. August 21, 1986 / Rules and Regulations 30031 l l

risks and dividing by the number of rotection, since the risk to the people should also be reasonably balanced and individuals residing in the vicinity of the ond 10 miles will be less than the supported through use of deterministic Pl ant. rien to the people within 10 miles. arguments. In this way judgements can in applying the objective for be made by the decisionmaker about the individual risk of prompt fatality the IV.Treatusesst of Uncer ral=Haa degree of confidence to be given to these Commission has defined the vicinity se %e Commission is aware that estimates and assumptions.nis is a the area within 1 mile of the nuclear uncertainties are not caused by use of key part of the process of determining power plant site boundary, since unntitative methodology in the degree of regulatory conservatism calculations of the consequenas of afaammMng but are merely that may be warranted for particular saspor reactor accidents suggest that highlighted thmugh use of the decisions. %Is defense-in. depth individuals within a mile of the plant quantification pmcesa. Confidence in approach is expected to continue to site boundary would generally be the use of pmbebiliatic and risk ensum the protection of public health

' subject to the greatest risk of prompt assessment techniques has steadily and safety.

death attributable to radiological imprmd since the time these were used causes. If there are no individuals la the Rasetor Safety Study. In fact. Muidelmas For L_._ ,, ,

sesiding within a mile of the plant through use of quantitative techniques. . totion boundary an individual should, for important uncertainties have been and %e Commission approves use of the

! evaluation purposes, be assumed to continue to be brought into better focus qualitative safety goals, including use of reside 1 mile fmm the site boundary. and may even be reduced compared to the quantitative health effects objectives in applying the objective for cancer those that would remain with sole in the regulatory decisionmaking l f;talities as a population guideline for allance on detenministic process.De Commission recognizes i

individuals in the area near the plant, decialaamaHng To the extent that the safety goal can provide a useful

practkable. the t'amminalao intends to the Commission has defined the tool by which the adequacy of population generally considered subject ensure at ee quantitative techniques regulations or regulatory decisions

, to significant risk as the population ' "8"

• 7 08 8 8 regarding changes to the regulations can

within 10 mile? of the plant site.He - 8 8CC unt a Potennal uncensinte be luc _114kewise, the safety goals i

' bulk of significant exposures of the that niet so eat an esumste can be could be of benefit in the much more

• population to radiation would be made on the confidence level to be difficult task of assessing whether concentrated within this distance, and exi8 ting plants, designed. constructed l

thus this is,the appropriate population n mi so as a op ed t use and operated to comply with east and of mean estimates for purposes of for campanson with cancer fatality risks implementing the quantitative objectives #"'"I '*I" "I " * * * * " " " 9"*!*'Y ,*

! frorn all other causes. His objective with the intent of the safety goal pohey.

of this safety goal policy (Le., the 1 would ensure that the estimated mortality risk objectives). Use of the .H wever,in onfer t do this, the staff i increase in the risk of delayed cancer mean estimates comports with the will require 8pecific guidelines to use as fatalities from all potential radiation customary practices for cost-benefit a basis for determining whether a level releases at a typical plant would be no analyses and it is the correct usage for f safety ascribed to a plant is more than a small fraction of the year- purposes of the mortality risk cons! stent wi6 Ge safety goal pohy

, to-year normal variation in the expected comparisons. Use of mean estimates As a separate mauer. Se Cornmission i

cancer deaths from eonnuclear causes. does not however resolve the need to intends to review and epprove guidance Moreover, the prompt fatality objective quantify (to the extent reasonable) and to the staff regardmg suc,n

, for protecting individuale generally understand those important determinations. It is currently i provides even greater protection to the uncertainties invclved in the reactor envisi ned that this guidance would population as a whole.That is,if the accident risk predictions. A number of address matters such as plant quantitiative objective for prompt uncertainties (e.g thermal-hydraulic performance guidelines,incicators for fatality is inet for individuals in the assumptions and the phenomenology of operational performance, and guidelines immediate vicinity of the plant, the core-melt progression, fission product I0r conduct of cost. benefit a

, estimated risk of delayed cancer fatality release and transport, and containment This guidance would be vedden,nelyses.

from to persons within to miles of the plant loads and performance) arise beca :se of additional studies conrincted by the staff end beyond would generally be much a direct lack of severe accident and resulting in recommendations to the

lower than the quantitative objective for experience or knowledge of accident Commission.%e guidance would be cancer fatality.nus, compliance with phenomenology along with data related based on the following general i the prompt fatality objective applied to to probability distributions. performance guideline which is individuals close to the plant would in such a situation,it is necessary that proposed by the Commission for further generally mean that the aggregate proper attention be given not only to the staff examinatior>-

estimated societal risk would be a range of uncertainty surrounding Consistent with the imditional tumber of times lower than it would be probabilistic estimates, but stao to the defense.in-depth approach and the if compliance with lust the objective phenomenology that most influences the occident mitigation philosophy applied to the population as a whole uncertainties. For this reason. sensitivity requiring reliableperformance of were involved. The distance for studies should be performed to containment systems, the overo// mean i cveraging the cancer fatality risk was determine those uncertainties most frequency ofo lorge release of l 4

tiken as 50 miles in the 1483 policy important to the probabilistic estimates. todioactive matericls to the statement. The change to 10 miles could %e results of sensitivity of studies envimnment from a reactor occident be viewed to provide additional should be displayed showing. for should be less than 1 in J.000.000per protection to individuals in the vicinity example, the range of variation together year oficoctor operotson.

cf the plant, although analyses indicate with the underlying science or To provide adequate protection of the that this objective for cancer fatality engineering assumptions that dominate public health and safety, current NRC l will not be the controlling one. It also this variation. Depending on the regulations require conservatism in I provides more representative societal decision needs, the probabilistic results design, construction. testing operetion l

l l

i o 30032 Feder;l Registir / Vol. 51, No.162 / Thursday. August 21, 1986 / Rules and Regulations

- and maintenance of nuclear power emphasis to be given to eccid nt compromise.1 bellsva it is an objective plants. A defense-in-depth appmach has prevention and accident mitigation. that is consistent with the been mandated in order to prevent Such guidance is necessary to ensure recommendations of the Commission's accidents from happening and to that the principle of defense-in-depth is chief safety officer and our Director of ,

l mitigate their consequences. Siting in maintained.ne Commission's Advisory Research, and past urgings of the l less populated areas is emphasized. Committee on Reactor Safeguards has Advisory Committee on Reactor Furthermore. emergency response repeatedly urged the Commission to do Safeguards. Unfortunately, the so. As a step in that direction. I offered Commission stopped short of adopting e capabilities are mandated to provide additional defense.in-depth protection for Commission consideration the this guideline as a performance to the surrounding population. following containment performance objective in the policy statement, but i These safety goals and these criterion: em encouraged that the Commission is implementation guidelines are not willing at least to examine the in order to awure a proper balance meant as a substitute for NRC's between accident prevention and accident Possibility of adoptingit. Achieving such a standard coupled with the regulations and do not relieve nuclear saltisation. the mean frequency of containment failure in the event of a severe containment perfottnance objective

]

power plant permittees and limnsees imrn complying with regulations. Nor core damage accident should be less than s in given above would go a long way are the safety goals and these too severe core damage accidents- toward ensudng that the operating reactors suomasfully complete their implementation guidelines in and of Since the Chernobyl accident, the usefullives and that the nuclear option themselves meant to serve as a sole nuclear industry has been trying to remains a viable component of the basis for licensing decisions. However, distance itselfimm the Chernobyl if pursuant to these guidelines, accident on the basis of the expected nation's energy mix.

information is developed that is performance of the containments amund in addition to preferry adoption of app!! cable to a particular licensina the U.S. power reactors. Unfortunately, this standard now,I also believe the decision.It may be considered as one the industry and the Commission are Commission needs to define a "large factor in the licensing decisic.t. unwilling to commit to a level of release" of radioactive materials. I ne additional views of Commissioner performance for the containments. would have defined it as "a release that Asselstine and the separate views of would tesult in a whole body dose of 5 The argument has been made that we Commissione' Bernthal are attached- do not know how to develop rem to en individual located at the site containment perionnance cdteria boundary."%is would be consistent 1 Dated at Washington. DC, this 30th day of (accident mitigation) because core with the EPA's emergency planning 1 4 1988.

For the Nuclear Regulatory Commission. meltdown phenomena and containment Protective Action Guidelines and with response thereto are very complex and t'te level proposed by the NRC staff for '

Lando W. Zech. Ir.,

involve substantial uncertainties. On the defining an Extraordinary Nuclear Chairmas Occurrence under the Price-Anderson :

other hand, to measure how close a Additional Views by Comnu.ssioner plant comes to the quantitative Act. In adopting such a definition, the Asselstine on the Safety Goal Policy Commission would be saying that its guidelines contained in this policy

! . Statement statement and to perfonn analyses objective is to ensure that tl ere is no more than a 1 in 1,000,000 chance per

%e commercial nuclear power required by the Comenission's backfit

mie, one must perform just those kinds year that the public would have to be industry started rather slowly and evacuated from the vicinity of a nuclear cautiously in the early 1960's. By the late of analyses.1 find these positions inconsistent. reactor and that the waiver of defenses 1960's and early 19 O's the growth of the ne other argument against a provisions of the Price-Anderson Act industry reached a feverish pace. New containment performance criterion is would be invoked. I believe this to be an orders were ccming in for regulatory appropriate objective in ensuring that review on almost a weekly basis.%e that such e standard would overspecify result was the designs of the plants the safety goal. However, a containment there is no undue risk to the public health and safety associated with outpaced operational experience and performance objective is an element of the development of safety standards. As ensuring that the principle of defense-in. nuclear power.

experience was gained in operational depth is maintained. Since we cannot Cost-Bendt Analym characteristics and in eefety reviews. rule out core meltdown accidents in the foreseeable future. given the current I believe it is long overdue for the safety standerds were developed or Commission to decide the appropriate modified with a general trend toward level of safety,I believe it unwise not to establish an expectation on the way to conduct cost-benefit analyses.

stricter requirements. nus, in the early ne Comrnission's own regulations tir/O's, the industry demanded to know performance of the final barrier to a require these analyses, which play a "how safe is safe enough."In this Safety substantial release of radioactive substantial role in the decisionmaking Goal Policy Statement. the Commission materials to the environment, given a on whether to improve safety. Yet, the is reaching a first attempt at answering core meltdown.

Commission continues to postpone the question. Much credit should go to General Performance Guideline addressing this fundamentalissue.

Chairman Palladino's efforts over the past 5 years to develop this policy While I have previously supported an Future React

statement. I approve this policy objective of reducing the risks to an as statement but believe it needs to go low as reasonatly achievable level, the in my view, this safety goal policy general performance gu'deline statement has been developed with a fitrther.nere are four additional steady eye on the apparent level of aspecis which should have been articulated in this policy (i.e ". . . the overall mean frequency of a large safety already achieved by most of addressed by the policy statement.

release of radioactive materials to the operating reactors.%at level has been g, p environrnent from a reactor accident arrived at by a piecemeal approach to

- First. I believe the Commission should should be less than t in 1.000,000 per designing. constructing and upgrading of have developed a policy on the relative year of reactor operation.")is a suitable the plants over the years as experience

,t -

i Federal Regist:r / Vol. 51. No.182 / Thursday. August 21, 1986 / Rules and Regulations 30033 P

was gained with th'e plants and as the Commission were to find 100 percent offsite consequences deserves careful

. results of required tesearch became confidence in some impervious thought. Is it reasonable that Zion and i

available. Given the performance of the containment design, but ignored what Palo Verde, for example, be assigned the

. cunent generation of plants,I believe a was inside the containment, the primary same theoretical " standard person" risk, safety goal for these plants is not good mandate would be satisfied, but in all even though they pose considerably enough for the future. nis policy thlihood, the second would not. different risks for the US population as statement should have had a separate . Consistent with the fiammission's long- a whole? As they stand, these 0.1 pool that would require substantially standing defense.in-depth philosophy, percent goals do not explicitly include cetter plants for the next generetion. To both core-melt and containment argue that the level of safety achieved population density considerations; a

perfonnance criteria should therefore be power plant could be located in Central by, plant designs that are over 10 years clearly stated parts of the Commission's oso is good enough for the next Park and still meet the Commission's safety goals.

generation is to have little faith in the quantitative offsite release standard.

in short, this paddmg lacks a theme.

ingenuity of engineers and in the Maaningful aneurance to the public: I believe the Commission's standards

' potenual for nuclear technology.1 would substantive guidance to the NRC staff; should preserve the important principle aave required the next_ generation of the regulatory path to the future for the that site-specific populauon density be plants to be substantiaUy safer than the industry-all these should be provided quantitatively considered in formulating currently operating plants. by plainly stating that, consistent with the Commission's societal risk objective:

SepmWe Views of Comehr the = -"='s " defense-in-depth" e y req ng at f th e mUS Borothal on Safety Goals Policy g

gg) g,,[ core-damage accidents consequence of UA nuclear power plant I do not disapprove of what has been should not be expected, on average, to operations should not exceed some said in this policy statement, but too occur in the US more than once in 100 appropriate specified fraction of the sum much remains unsaid.ne public is years:. of the expected risk of fatality from all understandably desirous of reassurance (2) Containment performance at other hazards to which members of the since Chernobyh tne NRC staff needs nuclear power plcnts should be such UA population are generally exposed.

clearguidance % cany out its that severe acciderts with substantial respensibilities to assure public health I am L.ther concemed by the .

offsite damages are not expected, on arbitrary nature of the 0.1 percent and .afety; the nuclear industry needs to aversge. to occur in the US more than plan for the future. All want and deserve once in 1,000 years; incremental" societal" health risk to see clear, unambiguous, practical standard adopted by the Commission, a (3) He goal for offsite consequences safety obice:tives that provide the concept grounded in a purely subjective i should be, expected to be met after assessment of what the public might I Commission's answer to the question, conservative consideration of the  !

"llow safe is safe enought" at UA uncertainties associated with the accept.%e Commission shouId nuclear power plants. ne question estimated frequency of severe core- seriously consider a more rational remains unanswered. damage and the estimated mitigation standard, tied statistically to the It is unrealistic for the Commission to thereof by containment.' average variations in natural exposure expect that society, for the foreseeable ne term " substantial offsite to radiation from all other sources.

future, will iudge nuclear power by the damages" would correspond to the Finally, as noted in its introductory same standard as it does all other risks. Commission's legal definition of comments, the Commission long ago De issue today is not so much " extraordinary nuclear occurrence." committed to " move forward with an calculated risk: the issue is public " Conservative consideration of explicit policy statement on safety acceptance and, consistent with the associated uncertainties" should offer at philosophy and the role of safety-cost intent of Congress, preservation of the least 90 percent confidence (typical good tradeoffs in NRC safety decisions."

nuclear option. engineering judgment,I would hupe) While this policy statement may not be In these early decades of nuclear that the offsite release goalis met. very " explicit", as discussed above, it power, BU-style incidents must be ne broad core-melt and offsite- contains nothing at all on the subject of rendered so rare that we would expect release goals should be met "for the "

• safety-cost

• tradeoffs in NRC safety to recount such an event only to our average power plant":1.e., for the decisions." For example, is $1,000 per grandchildren. For today's population of aggregate of UA powerplants.%e person-rem an appropriate cost-benefit reactors, that implies a probability for decision to fix or not to fix a specific standard for NRC regulatory action?

severe core damage of 10' per reactor plant would then depend on achieving While I have long argued that such year; for the longer term. It implies "the goal for offsite consequences." As a fundamental decisions are more rightly something better. I see this as a practical matter, this offsite societal risk the responsibility of Congress, the NRC straightforward policy conclusion that objective would (and should) be staff continues to use its own ad-hoc every newspaper editor in the country significantly dependent on site-specific

• understands only too well. If the judgment in lieu of either the population density.

Commission or the Congress speaking to Commission fails to set (and realize) this %e absence of such expheit objective then the nuclear option will the issue population density considerations in the In' summary, while the Commission cease to be credible before the end of Commission's 0.1 percent goals for the century. In other words, if TMI style has produced a document which is not events were to occur with 10-15 year in conflict with my broad philosophy in

. g,,,,,un,,y mA the commswan has regularity, public acceptance of nuclear .dopia propo.ed sons mitar to the above core. such matters. I doubt that the publi power would s!most certainly fail. melt sad contdameai performance objecove.-- expected a philosophical dissertat.c ion.

And while the Commission's primary C ken asether. the however erudite. It is a tribute to c"ommi.'h**

"h'*' . on e**Y".:'peran*t ti) o orrew prompt r.:. hey charge is to protect public health and Chairman Palladino's eflort: that the soak m pnrpo d e per.eper t*'P safety,it is also the clear intent of onsim ra e" crnerioca m communwrw io Commission has come this far. But the Congress that the Commission,if p=ide reasonabk ==rina . . thm a se=+ task remains unfinished.

possible, regulate in a way that * *"id*"' "*H '** "' m e u s preservos rather than jeopardizes the nuclear option. So, for example, if the N7t[ e sin plainly stated criterte svarsed abma.

n the p Doc. es-m N s-m e o amj

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