ML20043H259
| ML20043H259 | |
| Person / Time | |
|---|---|
| Issue date: | 05/08/1990 |
| From: | Remick NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9006220321 | |
| Download: ML20043H259 (3) | |
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SAMUEL J. CHILK, SECRETARY OF THE COMMISSION ga FROM:
C0lHISSIONER REMICK
SUBJECT:
SECY-90-146 -PROCESS, SCHEDULE, AND RESOURCES FOR THE REVIEW 0F EVOLUTIONARY AND PASSIVE ADVANCED LIGHT-WATER REACTORS APPROVED X in part DISAPPROVED X in part ABSTAIN NoT PARTICIPATING REQUEST DISCUSSION C0!MENTS:
SEE ATTACHED COMMENTS I
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COMMISSIONER REMICK'S COMMENTS ON SECY-90-146.
I UNDERSTAND AND SYMPATHIZE WITH THE VIEW THAT IDEALLY WE SHOULD APPROVE NEW DESICN CONCEPTS ONE STEP AT A TIME, IN A SERIAL i
REVIEW PROCESS.
HOWEvER, THE IMPOSITION OF SUCH A PROCEDURAL REQUIREMENT AT THIS DATE WILL GREATLY REDUCE OUR OPPORTUNITY TO PROVIDE EARLY FEEDBACK AND INFLUENCE ON THE SAFETY PROVISIONS OF SEVERAL OF THE PROPOSED DESIGNS AND COULD PREVENT FINAL DESIGNS AND CERTIFICATIOM REVIEWS FROM BEING COMPLETED BY THE TIME THERE IS A NEED FOR INDUSTRY TO DECIDE ON NEW PLANT ORDERS.
EARLY STAFF AND ACRS REVIEWS OF THE CONCEPTUAL ABWR AND PRISM DESIGNS HAVE RESULTED IN SIGNIFICANT SAFETY IMPROVEMENTS IN THESE DESIGNS.
THEREFORE, I CONTINUE TO BELIEVE THAT OUR REVIEW L
PROCESS MUST BE FLEXIBLE.
IT SHOULD INCLUDE BOTH SERIAL AND r
L PARALLEL EFFORTS FOR DESIGN CERTIFICATION, IN A MANNER WHICH PROVIDES FOR TIMELY DECISIONS ON TECHNICAL AND LEGAL ISSUES, AND TIMELY-COMMENTS ON THE COMMISSION'S VIEWS CONCERNING THE DESIRED CHARACTERISTICS OF ADVANCED REACTOR DESIGNS.
BECAUSE OUR OBJECTIVE IS TO CERTIFY A PLANT WITH ALL TECHNICAL ISSUES RESOLVED, IT,IS IMPERATIVE THAT WE ACTIVELY PARTICIPATE IN ALL AREAS OF THE DESIGN EFFORT IN A TIMELY MANNER.
THE RECENT DISCUSSIONS WITH STAFF ON WHAT CONSTITUTES A " COMPLETE" PLANT DOCUMENTATION, INCLUDING SEPARATE RULEMAKING VERSUS CERTIFICATION RULEMAKING ARE ISSUES AT HAND, WHERE SIGNIFICANT DELAYS IN THE CERTIFICATION PROCESS MAY EMERGE AND ILLUSTRATES THE NEED FOR l
EARLY DEFINITION OF ISSUES.
FURTHER, THE PROPOSED NEW DESIGNS L
OFFER MANY NEW TECHNICAL FEATURES.
IT IS ESSENTIAL THAT-THE STAFF REVIEW THESE DESIGNS TO ASSESS WHAT LONGER-TERM RESEARCH AND CODE DEVELOPMENT WILL BE NECESSARY TO PROVIDE INDEPENDENT AND TIMELY REVIEW OF THESE FEATURES.
I BELIEVE THAT THE NRC SHOULD ASSURE A THOROUGH REVIEW PROCESS, CONSISTENT WITH OUR AVAILABLE RESOURCES.
I AM CONCERNED THAT THE SERIAL-APPROACH WILL NOT IDENTIFY ISSUES UNTIL THEY BECOME CRITICAL PATH ITEMS.
THE COMBINED SERIAL AND PARALLEL APPROACH WHICH KEEPS THE COMMISSION AS ACTIVE PARTICIPANTS IN POLICY ISSUES APPEARS THE MORE LOGICAL APPROACH TO TAKE AT THIS TIME.
I BELIEVE WE HAVE SUFFICIENT RESOURCES IN THIS AGENCY TO FOLLOW THIS APPROACH WITHOUT IN ANY WAY COMPROMISING OUR ABILITY TO CARRY OUT OUR OTHER-REGULATORY RESPONSIBILITIES.
I BELIEVE THAT INDUSTRY HAS INDICATED ITS SUPPORT AND INTEREST IN FUTURE REACTOR DESIGNS.
ADMITTEDLY, NO NEW ORDER HAS BEEN l
PLACED, BUT IT IS DOUBTFUL THAT AN ORDER WILL BE MADE WITHOUT l
CERTIFIED DESIGNS BEING AVAILABLE.
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..g N.7 I THEREFORE APPROVE IN PART AND DISAPPROVE IN PART THE STAFF S I
PROPOSED PLAN OF ACTION.
I APPROVE THE PARALLEL REVIEW EFFORT IDENTIFIED BY THE STAFF, IN THAT POLICY ISSUES NEEDING REVIEW BY t
THE COMMISSION WILL BE RESOLVED SIMULTANEOUSLY WITH THE ONGOING STAFF REVIEW ACTIVITIES.
I DISAPPROVE STAFF'S PROPOSED LIMITED AREA OF INTERACTION WITH THE REACTOR DESIGNERS.
I AGREE WITH STAFF S PROPOSED i
INTERACTIONS BY " PARTICIPATION IN THE PLANNING AND OBSERVATION OF TESTING PROGRAMS AND APPROPRIATE DEVELOPMENT TO ADEQUATE COMPUTER CODES NECESSARY TO SUPPORT SAFETY ANALYSIS."
HOWEVER, I DO NOT BELIEVE THAT THIS EFFORT FULLY COMPORTS WITH THE OBJECTIVES OF THE COMMISSION S POLICY STATEMENT ON REGULATION OF ADVANCED NUCLEAR POWER PLANTS, IN WHICH THE COMMISSION STATED THAT ITS
" PRIMARY OBJECTIVES IN ISSUING AN ADVANCED REACTOR POLICY l'
STATEMENT ARE THREEFOLD:
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FIRST, TO ENCOURAGE THE EARLIEST POSSIBLE INTERACTION OF APPLICANT, VENDORS, AND GOVERNMENT AGENCIES WITH THE l
NRC:
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2.
SECOND,1TO PROVIDE ALL INTERESTED PARTIES, INCLUDING THE PUBLIC, WITH THE COMMISSION'S VIEWS CONCERNING THE DESIRED CHARACTERISTICS OF ADVANCED REACTOR DESIGNS; AND 3.
THIRD, TO EXPRESS THE COMMISSION'S INTENT TO ISSUE L
TIMELY COMMENT ON THE IMPLICATIONS OF SUCH DESIGNS FOR l
SAFETY AND REGULATORY PROCESS."
FOR EXAMPLE, SECY-90-146 STATES THAT "THE STAFF IS NOT PLANNING TO CONDUCT FORMAL CONCEPTUAL DESIGN REVIEWS FOR THE WESTINGHOUSE AP600 AND THE GENERAL ELECTRIC SIMPLIF1ED BOILING-WATER REACTOR (SBWR)."
I-BELIEVE THAT STAFF SHOULD CONDUCT SOME l'
FORM OF TECHNICAL REVIEW OF THE CONCEPTUAL DESIGNS IN ORDER TO OBTAIN REASONABLE UNDERSTANDING OF THE NEW DESIGN CONCEPTS; TO I
DEFINE RES AND LICENSING NEEDS; TO ENABLE THE STAFF TO UNDERSTAND THE CONCEPTS AND IMPLICATIONS OF ISSUES IDENTIFIED IN THE EPRI REQUIREMENTS DOCUMENTS FOR PASSIVE PLANT DESIGNS; AND l
TO PROVIDE EARLY COMMENTS TO THE VENDORS WITHOUT ADDRESSING THE UNRESOLVED POLICY ISSUES.
I AGREE THAT THE POLICY ISSUES FOR L
PASSIVE PLANT DESIGNS SHOULD BE ADDRESSED THROUGH THE EPRI L
REQUIREMENTS DOCUMENT REVIEW PROCESS.
THESE ISSUES SHOULD NOT BE RESOLVED THROUGH THE REVIEW OF THE CONCEPTUAL DESIGN DOCUMENTS.
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