main categories. The first category relates to the remote possibility of a reactor accident that could result in the release into the environment of hazardous quantities of radioactive materials. The second category, which I shall discuss later, relates to those environmental problems associated with normal operation of nuclear powerplants particularly the environmental effects of planned releases of low levels of radioactivity and thermal discharges to the surrounding air and water.

To assure adequate protection of the public from reactor accidents, nuclear powerplants employ a defense-in-depth concept :

The first and most important line is the achievement of superior quality in design, construction and operation of basic reactor systems so as to ensure a very low probability of any malfunction.

The second consists of the accident prevention safety features such as emergency reactor shutdown systems, which are designed into the plant. They are intended to prevent any unlikely malfunction of the reactor systems from escalating into more serious problems.

The third consists of consequence-limiting safety features, such as containment shells-which we are beginning to see around the country to confine or minimize the escape of fission products if they should be released from the fuel and the reaction systems.

The Commission's efforts to assure nuclear plant safety go beyond judging the acceptability of individual plants. We have been conducting extensive safety research and development programs costing about $35 million per year and fostering industry efforts along these lines. We also have been emphasizing the need for management know-how, fostering the development of industry standards, and encouraging the development of trained personnel. These types of actions constitute a positive approach, characterized by thorough planning and advance preparation, which has contributed significantly to the safe introduction of nuclear power to date.

WASTE MANAGEMENT

Coming now to the second category-the environmental problems associated with normal plant operations-I shall first discuss the AEC's system of controls with respect to the management of radioactive wastes produced at nuclear powerplants.

Radioactive wastes are of two general types-high and low level -and it is important to distinguish between them. High-level wastes are produced during the reprocessing of spent fuel elements from nuclear reactors. I would like to emphasize that they are not processed or disposed of at the reactor site. The spent reactor fuel is removed from the reactor, securely packed, and shipped to a reprocessing plant. It is only during reprocessing, which is done under rigid control, that high-level wastes are removed from the fuel elements and concentrated in liquid form for permanent storage. While such storage has been safe and effective, the AEC and the nuclear industry have supported substantial research and development of radioactive waste management techniques, including efforts to convert the liquid wastes to solid form. We recently announced a proposed policy for handling the high-level wastes from nuclear powerplant

fuels. Under this policy, the liquid wastes will be further concentrated, changed into solids, and stored at a Federal repository.

The other category-low-fuel-refers to the very low levels of radioactivity such as those which occur in liquid and gaseous effluents discharged during the routine operation of nuclear reactors. The Commission's regulations in 10 CFR Part 20 on the radioactive content of effluent air and water control the maximum amount of radioactivity permitted to be discharged to the environment. These regulations are based on the recommendations of the Federal Radiation Council which are approved by the President for guidance of the various Federal agencies. As I indicated above, they reflect a consensus of the world's best available expertise.

The limits on concentrations of radioactivity permitted in any power reactor liquid effluent leaving the plant area, prior to dilution in a body of water, are sufficiently low that a member of the public could drink this water throughout his lifetime without exceeding the radiation protection guidelines recommended by the Federal Radiation Council and approved by the President. Concentrations in the effluents, of course, are further reduced by dilution in the body of water into which they are discharged.

Limits on rates of release of radioactive gases are based on a conservative calculation which-at the point of highest radiation level averaged over a year, on or near the site boundary-would result in an exposure to an individual equal to the FRC radiation protection. guidelines, if he remains on or near the site boundary for the entire year. Of course, at greater distances, radiation levels decrease due to diffusion, dispersion and decay of the radioactive material.

Monitoring programs are carried out by licensees, some States, the U.S. Public Health Service, and the AEC. The quantities of radioactivity released, actually released from these powerplants, are so small that it has been difficult to measure any increase in radioactivity above natural background levels in rivers and streams.

THERMAL EFFECTS

The thermal effect of heated discharges is the other environmenta effect of nuclear powerplants which has received much attention lately.

All types of steam electric generating plants release heat to the environment, although light-water reactor plants reject somewhat more than the most modern of today's fossil plants.

Advanced reactors under development will eliminate this disparity between nuclear and fossil-fired plants. In addition, thermal effects can be localized or minimized through suitable design measures. In some cases, alternative cooling methods such as cooling towers and ponds can be effectively utilized. Furthermore, there are indications that the waste heat from powerplants could be used beneficially in some situations. More research in this area is warranted.

We anticipate that the recently enacted Water Quality Improvement Act of 1970-which you, of course, sponsored, Senator Muskie -will go a long way toward solving the problem of thermal effects insofar as licensed nuclear powerplants are concerned. I will discuss the procedures under this act later.

OPERATING EXPERIENCE

Nuclear reactors of all types licensed to operate thus far have accumulated more than 780 reactor-years of operation without a single radiation fatality and we know of no instance where their operations have resulted in offsite exposure of any member of the public to radiation exceeding the annual limits recommended by the Federal Radiation Council. The licensed nuclear powerplants within this group have attained a total of over 90 reactor-years of such safe operating experience. This experience has shown that low level activity released during operation of licensed power reactors has been generally less than a few percent of authorized limits that I mentioned earlier.

AEC REGULATORY ORGANIZATION

My remarks thus far have dealt with essentially technical matters. Let us now turn to administrative organization and procedures, specifically a description of the AEC regulatory organization.

The AEC's regulatory organization includes three main independent units: the regulatory staff, made up of nearly 500 full-time personnel, the independent Advisory Committee on Reactor Safeguards, and the independent Atomic Safety and Licensing Boards. I want to emphasize that we have been successful in building up an organization with wide experience and expertise in radiological safety matters. The regulatory staff alone includes 200 technical professional personnel engaged in reactor licensing, reactor standards, and reactor inspection activities. Nearly all hold colleage degrees and almost half advanced degrees, 15 of which are doctorates. Their average experience in their fields is 12.7 years, and some 40 percent have at least 15 years of experience.

Because of the way the AEC is organized, there is a growing degree of communication between the people doing research, or familiar with it, and the regulators charged with making sure that nuclear plants are safe. This degree of interaction and communication is becoming especially important in the fields of biology and medicine and ecology, so that the research work can be related to our regulatory activities. This is one of the substantial benefits associated with having the Commission charged with overall responsibility for both regulatory and developmental activities. It adds to the strength of our regulatory staff without infringing on the independence of the various regulatory groups involved in the quasi-judicial process of reactor licensing which I will describe in more detail shortly.

AEC PUBLIC REVIEW PROCEDURES

The expertise of the Commission's regulatory staff is first brought to bear as part of the Commission's process for the review of applications for construction permits for nuclear power reactors.

These applications undergo four separate reviews-(i) by our separated regulatory staff (ii) by the AEC Advisory Committee on Reactor Safeguards, (iii) by an Atomic Safety and Licensing Board and (iv) by the Licensing Appeal Board or the Commission itself. I would like to discuss these reviews briefly.

The first step in obtaining a license to construct a nuclear plant usually is an informal safety review by the AEC's regulatory staff of the proposed plantsite. Then, when and if the formal license application is submitted, the regulatory staff also reviews the applicant's safety analysis report in sufficient detail to reach an independent judgment that the safety of the reactor is adequate.

In addition to this review, the Advisory Committee on Reactor Safeguards which, by law, is made up of experts from outside the AEC makes an independent evaluation of the project. Both the ACRS report and our regulatory staff report are made available to the public through a press release and in our public document room. The next step is a public hearing, a mandatory public hearing, conducted by a three-member Atomic Safety and Licensing Board, composed of one attorney qualified in the conduct of administrative proceedings and two persons with technical backgrounds selected from a panel of outside experts. After hearing the views of all parties, the hearing board makes a decision as to whether the license should be granted. That decision is subject to Commission review either formally on appeal by an affected party, or informally under Commission practice.

The Commission recently established an Atomic Safety and Licensing Appeal Board to perform certain functions which would otherwise be performed by the Commissioners themselves. One of the responsibilities delegated to this Board is the handling of appeals in those proceedings on license applications or authorizations that involve facilities in which the AEC has a direct financial interest. In addition, the Commission is authorized to delegate its review functions to the Appeal Board in cases in which the AEC has no direct financial interest. Since the Atomic Safety and Licensing Appeal Board was established, the Commission has exercised this authority by delegating its review functions to an Appeal Board in almost every case. After more experience is gained, we might envision delegating authority to this Appeal Board on a phased basis to take over completely the functions of the Commission in review of initial decisions of the atomic safety and licensing boards, which hear our facility licensing cases.

This four-level review is very thorough, as it should be. In fact, I know of no other new technology, or old technology for that matter, with its associated industry where there is such a painstaking safety review.

COORDINATION WITH FEDERAL AND STATE AGENCIES

In addition to these safety reviews, as a part of our licensing procedures we have been coordinating applications for construction permits with various Federal agencies. Under a memorandum of understanding between the Atomic Energy Commission and the Department of the Interior, which was agreed in 1964 I believe, which I worked on with Under Secretary Jim Carr of Interior, the Commission routinely obtains expert advice and recommendations on all projected nuclear powerplants from appropriate agencies of the Department. This practice involves the U.S. Geological Survey, the U.S. Fish and Wildlife Service, and more recently, the Federal Water Pollution Control Administration.

The Commission also receives advice from other Federal agencies on matters pertinent to its evaluation of the application. This includes, where appropriate, advice from the Environmental Science Services Administration, U.S. Department of Commerce (Weather Bureau) that is the ESSA of the Department of Commerce on meteorology, from the Environmental Science Services Administration, U.S. Department of Commerce (Coast and Geodetic Survey), on seismicity, from the Department of the Army's Coastal Engineering Research Center on coastal effects, and from the U.S. Naval Ordnance Laboratory on missile and explosive effects. Of course, we shall continue these consultations under the provisions of the National Environmental Policy Act of 1969, which I shall discuss later in my testimony.

The Commission's regulations also provide that State representatives are to be given prompt notice of the filing of an application for a nuclear powerplant to be located in their State. State agencies are afforded an opportunity at hearings to offer evidence, interrogate witnesses and advise the Commission as to the application without having to take a position for or against the granting of the application. In addition, in the case of every nuclear powerplant construction permit application, we routinely pass on to the State and to the applicant the recommendations of the Fish and Wildlife Service, including recommendations on thermal effects, and urge the applicant to cooperate with the States in this area.

RECENT LEGISLATION

As I indicated earlier, the Water Quality Improvement Act of 1970 will be of significance in assuring that the problem of thermal effects is solved for powerplants that require some Federal license or permit prior to their construction or operation. This act will require applicants for construction permits and operating licenses for any nuclear powerplant which will discharge effluent into the navigable waters of the United States to provide the AEC with certification from the State or interstate pollution control agency, or the Secretary of the Interior, as appropriate, that there is reasonable assurance that the plant will not violate applicable water quality standards. The AEC would generally be prohibited from issuing any such permit or license without having received this certification.

The National Environmental Policy Act assures that other environmental factors will be recognized at an early stage in the utility planning process in anticipation of any Federal permit or license that may be required. In this connection, the Atomic Energy Commission has recently issued an interim policy statement setting forth how the Commission plans to implement the National Environmental Policy Act in its regulatory activities pending more specific guidance from the Environmental Quality Council and the adoption of more detailed procedures by the AEC in conformity with that guidance. I would like to take a moment or two to summarize the statement.

Applications for licenses to construct and operate nuclear powerplants and fuel reprocessing plants will be transmitted by AEC for