ML20059A727
| ML20059A727 | |
| Person / Time | |
|---|---|
| Issue date: | 01/15/1993 |
| From: | Selin I, The Chairman NRC COMMISSION (OCM) |
| To: | Brooks T AMERICAN INSTITUTE IN TAIWAN |
| Shared Package | |
| ML20059A717 | List: |
| References | |
| NUDOCS 9401030102 | |
| Download: ML20059A727 (3) | |
Text
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UNITED STATES
[N NUCLEAR REGULATORY COMMISSION y.y 2
WASHINGTON, D. C. 20555
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d January 15, 1993 CHA!RMAN l
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Mr. Thomas S.
Brooks Director American Institute in Taiwan Taipei, Taiwan j
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Dear Mr. Brooks:
In response to your request for my reaction to the letter that Dr. Seaborg sent to his colleague in Taiwan, I have the following i
comments:
j 1.
The letter from Dr. Seaborg seems to be based on a f
misunderstanding of the relationship between the EPRI
" requirements" and the NRC codes.
a.
The U.S.
designs will be governed by the same NRC codes i
and standards that are currently-in place, and which l
are the results of more than 2000 reactor years of operational experience in the United States.
The designs will be subject to a rigorous review process to i
determine their compliance with these standards on a i
generic basis, rather than on a site-specific basis.
(See paragraph 4 below.)
i b.
The EPRI requirements do not represent additional-safety requirements.
Rather, they represent the combined experience of the operating utilities in l
setting out the characteristics that they wish to see in any new reactor, from the viewpoint of economics, ease of operation, and simplicity of licensing.
l c.
It is not true that the EPRI requirements are peculiar to the American experience -- the document includes the participation of nine international utility companies of organizations, including TPC, EdF (France), JAPC (representing the Japanese utilities), Nuclear Electric / UK, and VDEW (representing the German utilities).
The EPRI document is the closest thing to an international utilities' statement of requirements which exists.
d.
Finally, the NRC is reviewing the EPRI document only from the narrow viewpoint of its consistency with our safety standards and considerations, just to make sure 9401030102 930121 PDR COMMS NRCC CORRESPONDENCE PDR-j e
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that there are'no conflicts between the utilities' f
operational and economic considerations, and NRC's j
safety considerations.
The standing of the EPRI i
requirements document is based on its acceptance by the l
utilities involved, not on an NRC review.
i 2.
One of the main reasons that the American utilities formed I
the EPRI group, and that the international utilities participated in the study, was to establish the basis for a set of standardized reactors.
The advantages of a set of standardized reactors, not only for TPS's Lungmen project, j
but for the whole next generation of reactors installed anywhere in the world, are universally recognized (except in the referenced letter).
The evolutionary or one-of-a-kind approach, in which configuration control is lost and literally thousands of changes are made from one installation to the next, is one that all modern nuclear programs (US, France, Japan, etc.) are trying to outgrow, not to perpetuate.
3.
Dr. Seaborg's letter also appears to misunderstand or misstate the nature of the designs and the experience of the non-European vendors.
I a.
The "new" non-European designs consist of proven components, with only evolutionary improvements.
The
'l biggest advances.from current plants are in electronics, i.e. in control room design and in instrumentation and control (I&C) areas in which the reactor industry.has lagged behind other high technology industries.
All of the electronic innovations have been well demonstrated in other l
applications (e.g., aviation).
b.
The novelty lies in the system approach of combining
)
the best of these proven components and subsystems in a rigorously defined, rigorously analyzed, and rigorously maintained overall system, and defining this system fully in advance, before constructions begins.
(Also see paragraph 4 below).
c.
Dr. Seaborg's letter suggests incorrectly that European designs are up-to-date, while American designs were
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frozen 20 years ago.
It is true that there are up-to-date and excellent European designs, but the American l
designs are at least as up-to-date, since the American designs have continued to be built in the United States as well as abroad (e.g.,
in Korea, Japan and Taiwan itself).
4.
The changes involved in settling on and implementing a truly standardized reactor design are so far reaching that they
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have led the NRC to develop quite a new design approval process, which is, incidentally, the only one of its kind in the world.
This process (1) systematically separates out generic design issues from site-specific construction issues, and (2) provides the framework for maintaining strict standardization throughout the construction process and from one reactor to the next.
(The process does not set out new codes and standards -- these codes and standards are I
quite uniform throughout the world.
The novelty is in the I
process of showing conformance with the codes and standards,
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and in the emphasis on maintaining standardization throughout the life of the system.)
The end point of this safety review process is the Final Design Approval; I do not l
believe that any new reactor will be built in the United States without an FDA, which will support both improved safety and standardization.
In sum, as these points clearly indicate, a decision to require compliance with EPRI requirements is basically a business decision, not a safety requirenent.
Compliance with EPRI will go a long way towards achieving an FDA although additional requirements also have to be met to receive the FDA.
Conversely,
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a system could receive an FDA without meeting the EPRI requirements.
I hope that you will find these comments to be useful.
I sin;erely, M'
f Ivan Selin r
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