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OFFICE OF THE COMr..SSIONE R Mr. John J.
Taylor Vice President for Nuclear Power EPRI 3412 Hillview Avenue Post Office Box 10412 Palo Alto, California 94303
Dear John:
I just wanted to take this opportunity to thank you for the chance to meet this past week to discuss the wide ranges of issues on which the Electric Power Research Institute is currently working.
I found the presentations nest helpful and professional and I think that I can say on behalf of all of those who were present from the NRC that we learned a great deal.
In addition, it would be remiss of me if I did not make a special point of commending your staff for the thorough and professional presentations.
They were most informative.
If you would, please extend my appreciation to all who were involved.
Again, we appreciate your gracious accommodation of our visit and the time and effort that you and your fine staff devoted to making this a most rewarding trip.
With warm regards, Most sincerely, g
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Curtiss 9408160237 940629 PDR COMMS NRCC CORRESPONDENCE PDR v
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February 27, 1990 CHAIRMAN 5
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James M. Taylor Executive Director for Operations a
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Kenneth M. Carr m
SUBJECT:
STAFF INTERACTION WITH EPRI ON POLICY ISSUES ASSOCIATED WITH THE EPRI ADVANCED LIGHT-WATER REACTOR REQUIREMENTS DOCUMENT The Comission, in reviewing the proposed response to E. E. Kintner's letter of December 26, 1989 (CR-90-30, copy enclosed), has expressed concern that the staff may misinterpret the response to prohibit their conducting a dialogue with EPRI on matters related to policy issues that have been forwarded for Comission review ano approval.
In order to clarify this matter, I want to reiterate the Comission's view that the staff is free to engage in oiscussions with EPRI on policy issues prior to Comission review and approval of the positions being taken by the staff provided that EPRI is informed that these positions have not been endorsed by the Comission.
Because the outcome of these discussions may prove useful in resolving policy issues referred for Comission consideration, the staff should keep the Comission informed of its interactions with EPRI on such policy issues.
Please ensure that the staff fully understands the Comission's views on this matter.
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Kenneth M. Carr
Enclosure:
As stated cc: Comissioner Roberts Comissioner Rogers /
Comissioner Curtiss Comissioner Remick OGC SECY i
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,E WASHINGTON, D. C. 20565 February 27, 1990 CHAIRMAN Mr. E. E. Kintner, Chairman Advanced LWR Program Utility Steering Committee Electric Power Research Institute 3412 Hillview Avenue Palo Alto, California 94304
Dear ntner:
I am responding to your letter of December 26, 1989, in which you expressed concern about the progress of the Nuclear Regulatory Commission (NRC) review of the EPRI advanced light-water reactor Requirements Docr :.-+.
The Commission has now established the NRC priorities and a process for the review of evolutionary and advanced designs and the EPRI Requirements Document.
The priorities and process applicable to the EPRI Requirements Document are as follows:
When a clear domestic preference exists for a particular design, the NRC will assign the highest priority to review of that design.
Until such time, the NRC has assigned equal priority to the review of the General Electric Advanced Boiling-Water Reactor, the Combustion Engineering System 80+, and the EPRI Requirements.
Document for evolutionary plant designs, with a particular focus on resolving those evolutionary plant design issues that will carry over into the Requirements Document f or passive plant designs.
In order to reflect the significance that NRC places on the EPRI Requirements Document, the staff will highlight in the Safety Evaluation Report (SER) for each design those areas where the resolution of design-specific issues is different from that established through the review of the EPRI Requirements Document.
The Commission has decided that greater priority should be given to the review of the EPRI Requirements Document for passive plant designs over the review of individual passive plant designs so that the Require-ments Document will be in place before we embark upon detailed review of individual designs.
The Commission has asked the staff to forward policy issues to the Commission as they are identified so that the Commission can address these policy issues before a draft SER is completed.
With this procedure, the Commission should not need to be h t) N 9* W /-
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2 involved in the review and approval of all draf t cr final SERs for the evolutionary plant designs and the Requirements Document.
However, the staff will provide a copy of the SERs to the Commission for its information before the SERs are issued.
The Commission has under review proposed departures from current regulations for the evolutionary light water reactors.
Although these policy issues are currently before the Commission for consideration, I urge you to continue your dialogue with the staff concerning the resolution of open technical issues.
At Commission direction, the staff is revising the draft SERs on those Requirements Document chapters already issued, as well as the draf t SER for Chapter 5, to include an analysis of those areas where the staff is proposing to depart from current regulations and to add a statement that Commission guidance will be required before a final decision can be made on such policy issues.
The staff is also continuing its review of the balance of the Requirements Document chapters in accordance with the established priorities.
The schedules for -
the issuance of the draf t SERs are being revised at this time and will be provided to you following approval by the Commission.
Sincerely, Kenneth M. Carr
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1 Advanced LWR Program UTILITY STEERING COMMITTEE
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December 26,1989
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Mr. Kenneth Carr, Chairman Nuclear' Regulatory Commission l
Washington, D.C. 20555
Dear Chairman Carr:
Many nuclear utility executives have expressed to you their thoughts on the steps needed to permit construction of a new generation of nuclear power plants.
Utilities need designs that are safer, simpler to operate and maintain, and easier to i
license. Such designs are possible through an industry-wide commitment to i
standardization and to a utility-consensus commitment to a set of design requirements that clearly stipulate the functional characteristics and design features necessary to achieve these goals.
The responsibility to establish these " customer. driven" utility design requirements rests with the Utility Steering Committee of the EPRI ALWR' Program. Utilities view the ALWR Requirements Document not only as a sp=htion to the vendors, but also as our consensus industry position on generic safety and regulatory issues for future plants. Thus, the Requirements Document is important to utilities both in our interactions with NRC and in 'our interactions with the NSSS vendors.
As discussed during our September 20,1989 Commission briefing, the Requirements Document draft SERs are far behind schedule, and important issues are not being closed. These problems still persist today. The NRC Staff response to Chapter 5 is now 15 months overdue, and six of the eight remaining draft SERs are also overdue. This lack of progress on obtaining Requirements Document draft SERs is seriously impacting both Evolutionary and Passive Plant schedules. The ALWR Program needs response from NRC Staff to verify our requirements meet regulation and adequately resolve open safety and regulatory issues.
Given these concerns, John Taylor of EPRI and Bill Rasin of NUMARC met with Tom Murley on 13 December to review pmgress since our 20 Septemtier briefing.
We understand that the Commission is working toward resolution of these problems. We were pleased to hear that NRC is establishing review priorities that will generally meet U.S. utility needs, ard that NRC recognizes the important role of the Requirements Document in resolving issues generically. However, we also understand that Staff no longer has a schedule forissuance of Requirements Document DSERs, and that reviews continue to be virtually stopped, pending answers to questions on review policy, process, and priority.
EPRI AdvancaiWRP Apa$cf7pphp.
3412 Hmview Avenus, Palo Aho,CA M306
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Mr. Kenneth Carr December 26,1989 Page: 2 1
We understand that many issues considered " policy" in nature will be undergoing a lengthy Commission review. Further, we understand that Staff positions on pclicy issues should not be considered final until Commission concurrence. We appreciate that a broad policy perspective will be needed to resolve some issues.
4 We believe progress should continue while these process and priority issues are being reviewed. Further, our experience has been that technical dialogue with NRC Staff is not possible on an issue considered by NRC to be " policy", until that issue has been resolved with the Commission. We - would like NRC to adopt a' i
review policy that permits open technical dialogue at the staff level, and early definitive resolution of issues.
We recommend that NRC Staff be authorized to prepare and send to us draft SERs on Requirements Document chapters based on previously established agreements for an agressive 8-9 month review schedule. We suggest that draft SERs should not need the same level of formal internal NRC review as final SERs, and that prior Commission concurrence may only be required on the more significant policy issues. We believe we can work effectively with NRC Staff in this manner,.
and would intend to approach NRC management, and if necessary appeal to the Commission,if at any time technical' dialogue and progress toward resolution of these important generic regulatory issues is not satisfactory.
We will continue to work closely with senior NRC Staff management to resolve any further concerns over the Requirements Document review process,'and will keep you informed on our progress.
Sincerely, k
I E. E.
t r, Chairman i
Advanced LWR Program Commissioner Roberts /
cc Commissioner Rogers Commissioner Curtiss Commissioner Remick James Taylor /EDO Tom Murley/NRR John Taylor /EPRI Bryon Lee, Jr./NUMARC ALWR Utility Steering Committee 002L/GLV
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