ML20138K426
| ML20138K426 | |
| Person / Time | |
|---|---|
| Issue date: | 12/11/1985 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8512180428 | |
| Download: ML20138K426 (94) | |
Text
OEGINAL l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of:
COMMISSION MEETING Briefing on Policy '
Statement on Nuclear Power Plant Standardization (Public Meeting)
Docket No.
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t Location: Washington, D. C.
Pages: 1 - 83 Date: Wednesday, December 11, 1985 l
ANN RILEY & ASSOCIATES Court Reportcrs 851211 1625 I St., N.W.
hD PT9.7 PDR ~
Suite 921
~, 1 Washington, D.C. 20006 ,,
"(202) 293-3950 -
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5 6 This is an unofficial transcript of a meeting of the 7 United States Nuclear Regulatory Commission held on 3 12/11/85 . In the Commission's office at 1717 H Street, 9 N.W., Washington, D.C. The meeting was open to public 10 attendance and observation. This transcript has not been 11 reviewed, corrected, or edited, and it may contain 12 inaccuracies.
13 The transcript is intended solely for general 14 informational purposes. As provided by 10 CFR 9.103, it is 15 not part of the formal or informal record of decision of the 16 matters discussed. Expressions of epinion in this transcript 17 do not necessarily reflect final determination or beliefs. No 18 pleading or other paper may be filed with the Commission in 19 any proceeding as the result of or addressed to any statement 20 or argument contained herein, except as the Cemmission may 21 authorize.
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1 1 UNITED STATES OF AMERICA rm i
2 NUCLEAR REGULATORY COMMISSION 3 xxx 4 BRIEFING ON POLICY STATEMENT ON
$ NUCLEAR POWER PLANT STANDARDIZATION 6 xxx
? PUBLIC MEETING 8 xxx 9
10 Nuclear Regulatory Commission 11 Room 1130 12 1717 H Street, Northwest
( ; 13 Washington, D.C.
14 Wednesday, 11 December 1985 15 16 The Commission met in open session, pursuant to j 17 notice, at 10:15 a.m., the Honorable NUNZIO J. PALLADINO, 18 Chairman of the Commission, presiding.
19 COMMISSIONERS PRESENT:
20 NUNZIO J. PALLADINO, Chairman of the Commission 21 THOMAS M. ROBERTS,-Member of the Commission i
l 22 JAMES X. ASSELSTINE, Member of the Commission l
l l- 23 FREDERICK M. BERNTHAL, Member'of the Commission 24 LANDO W. 2ECH, JR., Member of the Commission 25 l
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1 Presenters seated at the Commission Table:
m 2 William J. Dircks 3 Victor Stello ,
4 Frank Miraglia 5 Cecil Thomas 6 ' Sam Chilk l L
? Herzel Plaine.
8 9 Audience speaker:
.0 william Olmstead 11 13
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1 PROC E ED I NG S 2 CHAIRMAN PALLADINO: Good morning ladies and 3 gentlemen. Today we have with us members of the Statt to 4 discuss SECY-85-382, the proposed Standardization Policy 5 Statement.
6 Early this year the Stati forwarded SECY-85-225, 7 which discussed the stati plans for formalizing the subject 8 policy. This is our first meeting with the Staff on this 9 subject.
10 In 1978 the Commission approved a standardization I
11 policy. That policy described the conditions that must be met 12 for each of the standardization concepts. Over the years,
- 13 this policy has been used extensively.
14 Recently, the Commission issued its Severe Accidents 15 Policy Statement which set forth licensing requirements for 16 new plant designs.
17 In addition, the Commission has proposed to the J
18 Congress drait legislation entitled Nuclear Power-Plant 19 Licensing Standardization Act of 1985.
20 To supplement _these actions, I believe it is s
21 appropriate for the Commission to-update the 1978 22 Standardization Policy Statement to reflect recent NRC i 23 initiatives.
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4 At the completion of today*s meeting, I.would s
25 like to get a feel from my fellow Commissioners to determine
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4 1 whether or not they feel they have enough information to act m
i 2 on SECY-85-382 in the near future, or whether additional 3 actions are needed. And if so, what those actions are: Such 4 as additional meetings or the need for getting additional 5 information.
6 Before turning the meeting over to Stati, do any of 7 my tellow Commissioners have any additional opening remarks at 8 this time?
9 COMMISSIONER ZECH: No.
10 COMMISSIONER ROBERTS: No.
11 COMMISSIONER ASSELSTINE: No.
12 COMMISSIONER BERNTHAL: No.
(T 13 CHAIRMAN PALLADINO: All right. Let me turn the 14 meeting over to Mr. Stello.
15 MR. STELLO: Thank you, Mr. Chairman.
16 What we want to do this morning is to present to you 17 the results of the Staff *s view on what the Commission ought 18 to adopt as.a Standardization Policy Statement.
19 There are two things that I think are important to 20 recognize in doing so. First is that we have had the benefit
, 21 of considerable discussion with the industry, who formed up a 22 special group under the chairmanship of John Ward, and brought 23 in the various representatives'of the industry, the utility
,. 24 organizations, representatives from architect / engineering
- O 25 firms and vendors to try to. describe to the best of their I
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1 ability what they thought was important as they saw the future rh
! 2 of nuclear power, and what options they felt was important in 3 a standardization policy that they thought were going to be 4 significant in revitalization of the nuclear industry.
$ We have had the benefit of those discussions, and 6 they have submitted to us their views. And we will be 7 discussing the comparison of what their views are versus what B we think, and where those differencts are, and why we have 9 those differences.
10 The second point that I think is important, is that 11 in recognizing that there needs to be a rather broad base of 12 standardization options for the interim; that the Policy j 13 Statement dces reflect that it is the Commission's desire and 14 intent that for the long term some of these other options 15 would, hopefully, move by the wayside and you would have a 16 true certified standardization concept. And that is recognized 17 in the policy.
18 I don't think that there is much more that one can 19 do than recognize that today, in light of the expressed 20 desires of the industry. They believe it is very, very 21 important, and we will get into some of the details as to why, 22 to have those options.
23 COMMISSIONER ASSELSTINE: Vic, let me ask you one i
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24 question on your interaction with the industry.
V l 25 I understand the AIF ettort. We also had a fairly l
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1 substantial submittal from EEI, and we had a presentation s
-2 about a year or so ago from EPHI.
3 MR. STELLO: Yes.
4 COMMISSIONER ASSELSTINE: In some respects it 5 appears that the EEI and EPRI ettorts were a bit different 6 than the AIF ettort, particularly in the aggressiveness to 7 which they wanted certain elements in the standardization; 8 namely more complete facility design.1 9 To what extent did you deal with those groups as 10 well, particularly since they would seem to more directly 11 reflect the customers? 11 those customers don *t see what they 12 want from a standardization policy and from standard design, t 13 it seems to me there aren't going to be any. If they don't 14 get what they want, they are not going to buy them.
15 To what extent did you involve them as well, as 16 opposed to just focusing on the AIF group as the industry 17 point of contact.
18 MR. STELLO: Well, the AIF group was heavily 19 represented by the utility industry, which is what I think --
20 I agree with you -- which is where the market is. It is who 21 buys them that is going to be important.
22 Of course, who builds them is also important. It i s 23 what is available.
24 And they had a fair representation on the AIF l
25 committee, and I stressed particularly that it was especially
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1 important for them to get that utility input because they 2 were, in fact, the customers and they would, in fact, determine 3 the market. And what we have in the way of ecmments from them 4 does to the best of our ability to get an industry view. It 5 did not go to someone like NUMARC, which I had hoped perhaps we 6 could get it to go to someone like NUMARC, be c atts e it then does 7 truly represent the utility industry view. It fell short of 8 that, but had representation of various members who are 9 associated with NUMARC 10 COMMISSIONER ASSELSTINE: Is it your view the AIF 4
11 ettort is truly reflective of the EEI work and the EPRI work J
12 as well?
13 MR. STELLO: I think some of the work in EPHI and 14 EEI is more in what I would probably call advanced-reactor 15 concept as a porsibility, rather than in standardization. We 16 are really talking about starting from scratch in terms of 17 designing, not using existing designs, as much as the concept 18 that AIF felt was very important.
19 The things that you hear over and over again is the 20 industry, especially the. utility end of it, that if they are 21 going'to build another power plant, what they are going to 22 'look for is a power plant that has a good record.
23 CCMMISSIONER ROBERTS: You bet. Replication. They 24 are not going to start from scratch with some new grandiose
[ 25 design. That's crazy.
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3 1 MR. STELLO: That*s the thing that they felt for the N
2 next plant that they might be interested in, that is the kind 3 of experience. They want those drawings that are complete 4 drawings, that have a complete set of construction drawings 5 to start with. A complete design. No question as to what the 6 design is. They know what kind of a maintenance history, they 7 know what kind of a training program they have to have. All 8 of the attributes that they need to make a plant run well in 9 front of them and can really copy that kind of a concept.
10 That is what you hear over and over from the industry 11 as the thing that they feel for the short term is very, very 12 important.
13 COMMISSIONER ASSELSTINE: Which utility executive 14 has said that he or his company is interested in replicating 15 an existing plant within the next five or ten years?
16 MR. STELLO: I don't know of anyone --
17 COMMISSIONER ROBERTS: No one with any sense.
18 MR. STELLO: -- who has indicated that they are 19 about to make that commitment. But all of the conversations 20 that I have had were that-it they were going to make the 21 commitment, this is what they would consider as the most 22 logical course to follow.
23- MR. MIRAGLIA: I think in our interactions with the i
24 AIF, I think it was clear what the EPRI effort is. But 25 certainly, I think the EPHI effort would be consistent with
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1 one of the concepts that is proposed in the policy statement, m
j 2 the reference design concept.
3 And the industry was also very interested in 4 maintaining the other options in the near term and in the 5 short term.
6 I think in the discussions we had at the AIF,
? Commissioner Asselstine, to respond to your last question, I 8 think before a utility executive would make a decision about 9 replication or duplication, they feel that this policy 10 statement would set the stage for that kind of decision base 11 to be met. And so, I think they see it as an important first 12 step towards those kinds of decisions,
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13 CHAIRMAN PALLADINO: But I have a problem. Based on i
14 what you tell me the industry wants, I don *t understand why we 15 talk about not only an entire plant design, but standardizing 16 a portion thereof 17 It is my impression, and I didn*t get it only in the 18 last five years, I have had it for quite a while, that the 19 whole plant is an integrated system, and the interaction 20 between parts of the plant, be it balance of plant or nuclear 21 steam supply system, is very important in knowing whether or 22 not you have got a good reliable design.
23 Why do we talk about standardizing a major portion 24 thereof --
and that is throughout the whole document --
25 because if I hear the industry right, they would like to do
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10 1 exactly whit you said, build a plant for which they have a j 2 complete design and whose characteristics they know well, and 3 that has some proven record of reliability.
4 'MR. MIRAGLI ; TL think that it one looks at g<
5 standardisation and the implementation of it, since the early
~- 6 *?Os and through *?8 and beyond, .thert was a clear distinction 7 between NSSS and balance of plant. And as we have come down 8 the path in time of tmplementation, the scope'of the designs 9 being put before the Staff are certainly much broader. That 10 was particularly true in the sense of the GESSAR application 11 -#ith the nuclear island, which was essentially the entire 1? plant except for maybe the turbine island, and in the
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13 Westinghouse RESSAR review, that is also the case.
14 CHAIRMAN PALLADINO: SA why.si.ould we perpetuate 15 't hat 4hinking?
16 MR. MIEACb!A: Well, I think it has the options 17 there, whether people avail themselves of that option would 18 remain to be seen. And I think it is also consistent with the ld ' . language that is in the proposed legislation, sort of had, 20 which the Commission forwarded to the, Congress in *85, still 21 had that -- elements of that concept there- So, we preserved
. 22 them in the policy statement.
9 23 1.'2 one looks at the legislative package that we 24 sent --
20- zCHAIRMAN PALLADINO: I haven *t looked at it lately.
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- 15 1 I don *t remember that, so I will have to look at it again.
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. ,/ -2 MR. MIRAGLIA: I think it was there in '82, 3 CHAIRMAN PALLADINO: Maybe that was a tailing of the 4 package.
5 MR. MIRAGLIA: We made some language changes that 6 strongly encouraged the complete design between the '82 and 7 the '85 legislative package, but that option was still there.
8 And on that basis, that language was retained in that policy 9 statement.
10 CHAIRMAN PALLADINO: Well, I'm not sure whether we 11 might not be misleading people it we talk about standardizing 12 a portion of the plant, because these plants do have 13 interactive systems and components that very much affect the 14 reliability and the operation characteristics of the plant.
15 Well, okay --
16 COMMISSIONER ASSELSTINE: I very much agree with 17 that, Joe. I think you are right. And if the reason that we 18 are doing that here is because that is the way the legislation 19 was worded, maybe we ought to rethink that because --
20 CHAIRMAN PALLADINO: I'll have to go back and reread 21 the legislation. I haven't read it in a while.
22 MR. STELLO: I think there are some underlying
, 23 reasons-about the structure that we have in the industry that l 'd 4 causes that to happen, too. You have had historically the is 25 tour major nuclear steam suppliers, who were looking at ways
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in which.to standardige their portion of the plant. And they
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2 started to come in.
3 Now, when you have that portion of the plant s
4 standardized, and thenDyou have a much larger number of 5 architect / engineers wholwant then to get into the balance of s
6 plant design, and come.in with what they consider the' balance 3 r
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? of plant desfgn that was standard for anyp one of those four 8 different suppliers, we are talking abouk'a fairly large s
9 number of combinations that were pos s i bl e~.
10 Now, it is more difficult in the interface problems 11 in terms of trying to describe the nuclear island or smaller 12 portion of a plant in terms o' t nuclear steam suppliers' end of i
l~ 13 the business. But it was necessary because that is the way t
14 they were, in fact, going about conducting their business.
i IN That is the portion of it they_were sell'ing, and they were i
16 standardizing that portion that they were selling, which is a
-s 17 good idea.
rx 18 And you had that being a standard package offered 19 to anyone who is going to build a plant. And at least that ,
x 2' U' portion of it you had iairly high-lbonfidence that you knew 21 what was in'it, you didn*t need to go over a,n d review that 22 over and over again. .You had a fairly good basis for i>
concluding;that you understood ~ t h a ti . p o r t i on of the design.
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24 But that diy not mean that when you then got the xs / .
25 balance _ of plant-designer in, that.you had to look at the rest
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13 1 et it-to make sure it would work out okay.
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]! 2 COMMISSIONER ASSELSTINE: That's an accurate 3 historical picture, I think. But I also think that that 4 identities the heart of the problem we have had in this 5 country. And it we are going to have a standardization policy 6 that says, not only are you going to have perhaps two or three 7 standardized NSSS designs, but than you are going to have 8 another batch of so-called standardized balance of plant.
9 And then when you put all those things together, you 10 end up with 20 different plants out of the next 20 plants 11 ordered, it seems to me that is not achieving what we want to 12 achieve on standardization. In essence, what we may be 13 creating is the illusion that we are going to have 14 standardization, and in actuality what we will have is more of 15 the same. More custom plants.
16 When you put together what supposedly is a 17 standardized NSSS and supposedly a standardized balance of 18 plant, .and you put together lots of different combinations, 19 you are still going to end up with lots of different plants 20 and the same kinds of problems that we have had in the past.
21 MR. STELLO: -And that was recognized. That's why I 22 said at the outset that the policy statement indicates that j 23 for the long term, the Commission does not want to continue 24 this process. It'is in in a transition period where it is 25 going to be necessary --
at least based on what we hear from
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14 1 the industry -- necessary 11 they are going to be building n
j 2 another plant. And there are a lot of reasons behind that 3 which I think are significant.
4 But, for that long term what we want to achieve is a 5 truly certified, codified standard plant embodied in our 6 regulations, so that 11 someone in the future wishes to build 7 a plant, they can come to our regulations and there is a 4
8 preapproved plant in the regulations, hopefully some day a 9 preapproved site. They can pick the two of them together and 10 then only need to deal with those things that are outside of 11 either the site or the plant.
12 And that, hopefully, is the ideal that the Commission 13 would like to achieve in the long term.
s 14 COMMISSIONER BERNTHAL: Let me see if I can 15 understand, express, perhaps, the problem here in a different 16 way.
17 It seems to me that-what you are really up against 18 is that at some point, in your standardized plant design -- at 19 _some point maybe isn*t the right word -- at some circle around 20 it, your steam steam supply system, the specificatiens for the
.i 21 plant change from, let's say, Westinghouse, or GE or Combustion 22 or whoever it might be, to where it-is no longer a 23 Westinghouse, GE or Combustion, but it then makes a transition 24 that one hopes is smooth, and in a nevertheless integral 25 package to specifications that can be fulfilled by the
o 15 1 architect / engineer, by any of the various several 2 architect / engineers.
3 Is that what we are talking about here, so that they 4 objective really is finally to have a rather complete package, 5 but we go from a nuclear steam supply system that is basically 6 single vendor -- it is one of the three or four -- to 7 specifications on balance of plant. But, for a variety of 8 reasons, including antitrust, I suppose, reasons, that balance 9 of plant, thougn specified, would be tilled by various 10 architect / engineers.
11 Is that sort of what we are talking about?
12 MR. STELLO: Yes, that is one of the options.
13 Maybe it would be best it we could go through the 14 presentation, we could see -- we are picking bits and pieces 15 out rather than seeing the whole picture panoply of options 16 that are there.
17 Maybe 11 we could just go through that so you could 18 see them all.
19 CHAIRMAN PALLADINO: That's good.
20 COMMISSIONER BERNTHAL. Can you answer me very 21 quickly, though, institutionally, is that kind of what you 22 envision?
23 MR. STELLO: I think short answer, that is one of 7
24 the options.
25 MR. MIRAGLIA: And I think it is an accurate
56 1 representation, as Commissioner Asselstine said, of where we 2 have been in the past. I think it one goes back to the early 3 applications of standardization policy. the scope of the NSSS 4 design was much more constraining than what we are seeing now.
5 Certainly, it one wants to take full beneilt of a 6 replication or duplicate concept.that we are thinking about, I 7 think it is in the best interest of everyone concerned to make 8 that scope as broad as possible so that the interface 9 requirements are very small and very easily understood.
10 COMMISSIONER BERNTHAL: But the constraints are 11 driven by the institutions involved, not by any particular 12 desire on the part of the Commission --
<' 13 CHAIRMAN PALLADINO: Or on the utilities.
14 COMMISSIONER BERNTHAL: -- because there are four 15 vendors or three? They are sellers.
16 MR. MIRAGLIA: That*s correct.
17 CHAIRMAN PALLADINO: I agree, we ought to go through 1
18 the presentation. But, Commissioner Roberts had a few --
19 COMMISSIONER ROBERTS: I had a question for Jim.
20 You said what we want in standardization. Would you 21 give me a definition of what we want for standardization?
22 COMMISSIONER ASSELSTINE: What I would like to see l
23 is a standardization program that leads to the development and 24 use of a few, essentially complete, standardized designs, Not l
25 one, but perhaps two or three. standardized designs for this
o 17 1 country that when the utility comes in and says, we are ready I 2 to start building the plant, the design is sutticiently 3 complete so that all safety issues can be resolved before the 4 first shovel of dirt is turned and where we are dealing with 3 just a few basics;1y complete standard designs.
6 I-don't think we can get to one, but I think we 7 could get to just a few. Rather than having this combination 8 of matchups that would lead to -- say 11 20 more plants are 9 ordered, 20 different plants. I think that has been part of 10 the problem both for us and the industry in the past, and I 11 think it benefits both the regulators, the public and the 12 industry if we can get away from that for the future.
13 That is what I would like to see. And I think there 14 is a public benefit in doing that.
15 I also think there is a commercial benefit, a 16 benefit to the ratepayers, and a benefit to the public in 17 terms of safety.
18 I think it we get into the situation where we are 19 building 20 different plants again, it is going to be more of 20 the same kind of trouble. You get the systems interaction 21 problems that Joe is talking about, you get the difficulty in 22 supply that the utilities now face, the difficulties in 23 sources of supply for components, replacement parts, equipment, 24 difficulties in maintenance.
25 We would just be much better off 11 we could get to
18 1 a fewer number of essentially complete designs, get all the
(%,' 2 safety issues resolved before you start to build the plant, so 3 that we are not changing the designs or trying to address 4 safety issues while construction is going on and get this 5 mishmash of evolution through the construction and operation 6 process.
7 That is what I would like to see.
8 COMMISSIONER BERNTHAL: All of that is fine, but I 9 don't think that we should be under any illusion that 10 standardized plant design means standardized nameplate.
11 Because that simply, as I read what little I know about 12 antitrust law and the Commission -- after all, we are not the
'T 13 first ones to sit here and debate this issue. Much of that, 14 part of it was gone through in the 1970s. And there is no 15 way, as I understand it, that you were going to specify 16 nameplate throughout the plant. You can't do that. It has 17 got to be a standard design, not standard nameplate.
18 COMMISSIONER ASSELSTINE: Yes. On components I 19 agree with that. But we should be able to specify and resolve 20 design issues prior to the start of construction. I think to
-21 the point where you may not specify it has to be a certain 22 kind of pump or a certain kind of valve, but these are the 23 performance characteristics you want from that piece of l
24 equipment in order to ensure that any safety issue that we
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- 25 have a concern about about that system or component, is
19 1 settled. So that we aren't. finding out that there are vastly.
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2 different performance characteristics when they decide which 3 component they are going to use in a particular part.
4 At least that is my perception. I think, Lando, you 5 have been talking much along the same lines.
6 COMMISSIONER ZECH: I feel very much the same. I 7 think that we ought to listen to the Statt first. I do have 8 some thoughts on it. But, I am pretty much in agreement with 9 Commissioner Asselstine's views in this regard.
10 Mr. Chairman, I would suggest we let the Stati --
11 CHAIRMAN PALLADINO: That's where I am trying to go.
12 However, I feel compelled to make one other comment.
13 Even though we talk about a few standard designs, 14 there may be standard design with a sub-A and a sub-B; A being 15 in one seismic area and B in another. But, I think we are 16 probably in closer accord than may first appear.
17 COMMISSIONER BERNTHAL: We'll probably learn more 11 18 we listen rather than talk.
19 CHAIRMAN PALLADINO: That's right. As I tell myselt 20 once in a while, I ain't learning when I'm talking.
21 MR. MIRAGLIA: With your permission.
22 May I have the first slide, please.
23 [ Slide.]
24 This is just an outline of the points we would like 25 to cover today.
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1 Briefly the background of the standardization policy i
2 and how it evolved over the last decade, the need for us 3 taking some action and revising the existing policy statement 4 that is now on the record.
S What present standardization concepts we think 6 should be retained, and the reasons for retaining those 7 concepts.
8 We will point out the differences in the proposed 9 revisions to the '78 policy statement that is articulated 10 in the present proposal before you. Discuss the transition 11 replicate provisions and the need for those. And identity for 12 you the differences between what the Staff was proposing and s 13 what was in the AIF proposal that was enclosed as part of the 14 Commission paper on the subject.
15 May I have the next slide, please.
16 [ Slide.]
17 Standardization, as I said it has been involved over 18 the last decade or more. The initial policy statement was 19 issued in 1972; clarified in March of '73 with specific 20 identification of three standardization concepts. A reference 21 system concept, a duplicate system concept, and a manufacturing 22 license concept.
l 23 In August of 1974, that policy statement was revised l
! 24 to articulate an additional concept, which is the replicate 1
25 plant concept.
28 1 In 1977, the Commission reaffirmed its support for 1
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2 standardization and asked for additional comments and 3 suggestions to determine how that policy, the existing policy 4 should be modified. That was done, and the most recent policy 5 statement was issued in 1978.
6 May.I have the next slide, please?
? [ Slide.]
8 Since that time, the Statt has had considerable 9 experience in implementing the various standardization concepts 10 that were outlined in the 1978 policy statement. There were 11 many issuances of PDAs, construction permits, and final design 12 approvals utilising the reference plant concepts.
13 In addition, there were numerous construction 14 permits issued under the duplication concept. Three of those 15 cps that were issued, actually have come to fruition in terms 16 of operating licenses. Byron and Braidwood being examples of 17 those.
18 And, there were a number of replicate plant design 19- concepts that were put before the Staff that were the basis 20 for issuance of cps, but no OLs have resulted from those 21 reviews. And in addition, it was the manufacturing license 22 which was issued in about 1982 for eight units to be built by 23 Westinghouse.
24 CGMMISSIONER ASSELSTINE: Are there any replicates 25 that are still under construction? Active construction?
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22 1 MR. MIRAGLIA: To the best of my knowledge, no.
2 COMMISSIONER ASSELSTINE: 11 WNP-3 were reactivated, 3 would that be one?
4 MR. MIRAGLIA: WNP-3 would be a reference. It 5 references CESSAR. It is a system 80 plant, so it would be 6 under the reference design concept.
7 Marble Hill would --
8 COMMISSIONER ASSELSTINE: Was a replicate?
9 MR. MIRAGLIA: -- was a replicate of the Byron, 10 Braidwood, which was a duplicate.
11 COMMISSIONER ASSELSTINE: Okay.
12 COMMISSIONER BERNTHAL: I'm confused. We have got 13 Palo Verde 1 and 2. Now isn't there 3 coming?
14 MR. MIRAGLIA: Yes, sir.
15 COMMISSIONER BERNTHAL: That's a replicate, is it 16 not?
17 MR. MIRAGLIA: It is a reference plant design. It 18 is a system 80 plant. All three reactors would be --
19 COMMISSIONER ASSELSTINE: They'are duplicates, but 20 they started with the reference design, right?
21 MR. MIRAGLIA: They started with a reference design.
22 COMMISSIONER ASSELSTINE: And then they built 23 several according to that reference design.
24 MR. MIRAGLIA: Duplicate is sort of a special case 25 --
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23 1 COMMISSIONER ASSELSTINE: It is a custom plant where 2 you just build another custom plant just like it at the same
- 3 site, right?
4 CHAIRMAN PALLADINO: At the same site -- Could you 5 refresh me. I have trouble with replicate and duplicate.
6 MR. MIRAGLIA: I have a slide on that, sir. '.
7 CHAIRMAN PALLADINO: Okay. 7 f
8 MR. MIRAGLIA: It is on the next slide. If I can go 9 through this one, I'll get to that.
10 CHAIRMAN PALLADINO: I'll wait. Thank you. l 11 [ Commissioner Roberts left the room.] f i
12 MR. MIRAGLIA: In addition, since 1978, we have had ,
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' ./ 13 various considerations on the severe accident policy 14 statement. And in that policy statement the Commission has 15 articulated additional requirements that new designs should i
16 consider; compliance with the current rules, regulations of 17 the Commission, compliance with the CPML rule, technical 18 resolution of unresolved safety issues, and high priority i
19 generic issues, the conduct of a PHA and the combination of a 20 deterministic and completion of a deterministic review, 21 considering the insights from that PHA *o establish what the ,
22 design basis for the new plants would be.
23 In addition, there is the proposed legislation that 24 also has certain concepts in it that are related to the 25 standardisation policy. That legislation was proposed, I
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1 believe --
reproposed to the Congress in January '85.
m
' 'M 2' And that'has'tho' concepts of a combined CP-OL. It 3 had the incentive of waiving. fees, set up a design approval 4 process to consider ten years design certification process, 5 and it set a threshold for changes in that standardized 6 design.
1 ? -CHAIRMAN PALLADINO: Which one was this?
4
, 8 MR. MIRAGLIA: This is in the Licensing Reform Bill, i
~
9 and the Standardization Act of 1985.
10 And as a result of considering all of these, what 11 you have before you is a Stati proposal that represents our 12 current views on how these various pieces-should be put
,f)
- (;j 13 together to modify the existing pol' icy.
14 within the proposed policy statement we.have retained t
. 15 the present standardization concepts, the reference system 16 concept. And that is an application for approval or i 17 certification of an entire plant or major po'rtion of a plant
, 18 without having a specific application before us, a specific 1
19 identified site.
20 It would be a design for a plant such as GESSAR.
4 21 The GESSAR review was done under the reference plant concept.
.22 The RESSAR 90 review was being conducted. It is a-reference
[- 23 system. It is a design of a major portion of a nuclear power i
24 plant, and that review is being conducted. There is not a a
25 specific application at which that design would be put on a l
l l
I
. . _ . - - . , , , ~ . , . _ - - - . . . . _ . _ , . . . _ .. _ _ _ , . - _ . . ,,.m..., _. _ _ _ . . _ _ _ _ . - , - - _ _..,_._-.___.,,,.m
25 1 site and be used at this point in time.
. -' J.
2 A duplicate --
3 COMMISSIONER ASSELSTINE: Can you give us some
'4 examples, then, of plants that have been built using each of 5' these elements.
6 MR. MIRAGLIA: Sure.
? COMMISSIONER ASSELSTINE: Palo' Verde, I take it, is 8 one.
9 MR. MIRAGLIA: Palo Verde is a reference plant 10' design. We had -- Hartsville would have been an example of a 11 reference plant design. It was a forerunner of the current 12 -GESSAR.
(h N/ 13 ' COMMISSIONER ASSELSTINE: Okay.
14 MR. MIRAGLIA: Those would be examples of a reference 15 system design.
16 Duplicate plant would be an application for licenses 17 for a number of plants of essentially the same design at 18 different sites. An example of that would be Wolf Creek and 19 .Calloway. That was part of a SNUPPS application. The original 20 SNUPPS application was for six or eight units, having Sterling
~21 and several other projects.
22 But, as examples of OLs that have been built under 23 that concept, you would have-Calloway, Wolf Creek.and certainly
_, 24 2yron and Braidwood are duplicate plants. And Byron is
-25 licensed, and two Braidwood units and the additional Byron
26 1 unit is currently under review now.
i 2 CHAIRMAN PALLADINO: Why do you say at different 3 sites? What would be wrong with doing it at the same site *r 4 MR. MIRAGLIA: Well, essentially you have a 5 combination of both. Byron 1 and 2 are at the same site; 6 Braidwood 1 and 2 is a duplicate --
7 CHAIRMAN PALLADINO: You don *t say "or at the same d
8 site," and I'm having a little trouble to find out the 9 distinction between duplicate and replicate. At first I 10 thought it was site-related, but now you tell me it isn*t.
11 COMMISSIONER BERNTHAL: None of them are 12 site-related, are they?
p x _./ 13 MR. MIRAGLIA: No, sir.
14 CHAIRMAN PALLADINO: Well, this one says a oi 15 essentially the same design at different sites."
16 MR. MIRAGLIA: At different sites.
17 CHAIRMAN PALLADINO: So, I thought that --
18 MR. MIRAGLIA: Or, it could be the same site.
19 CHAIRMAN PALLADINO: Okay.
20 Well, I am having difficulty. The distinotion seems 21 to be difficult to follow because I don *t understand --
22 MR. MIRAGLIA: The major differences come out when 23 one looks at the concepts, is determined in referenceability 24 of the various designs and the time at which the review was 25 conducted.
l l
, , _ . w ,-. , ,,m, - , , .
m U.
27 1 CHAIRMAN PALLADINO: No, I am trying to understand 2 duplicate and replicate. So, why don't you go ahead with 3 replicate.
4 4 MR. MIRAGLIA: Replicate is an application for one 5 or more plants, essentially of a design that has already been o licensed. A duplicate would not necessarily have to be. One 7 difference would be, a duplicate design would not have to 8 have already been licensed in order to be duplicated. However, 9 a replicate would be a design at a different site or at the 10 same site of an already licensed design.
11 CHAIRMAN PALLADINO: So that is the basic 12 difference. Duplicate is --
^
13 COMMISSIONER ASSELSTINE: It is really timing.
14 MR. MIRAGLIA: It is the timing of the review and 15 the application.
16 COMMISSIONER ASSELSTINE: Duplicate they all come in 17 together. Replicate, you go back later on and say, hey, we 18 want to build another one just like we built here.
19 MR. MIRAGLIA: Yes. The review is essentially 20 complete. You could come in for a duplicate design while the 21 other. review was ongoing.
22 CHAIRMAN PALLADINO: Okay.
23 MR. MIRAGLIA: .And the manufacturing license was a 24 specific application to manufacture a specified number of 25 identical plants at a location other than where the plant L
m
- 28 1 would be operated. And that was the floating plant concept, 3
2 which resulted in the utilization and manufacturing license.
3 COMMISSIONER ASSELSTINE: And we've had no 4 replicates, so far.
5 MR. MIRAGLIA: Well, we have issued cps under the 6 replicate concept. There have been no Obs.
7 COMMISSIONER ASSELSTINE: They have all been 8 cancelled.
9 MR. MIRAGLIA: Jamesport and Marble Hill were 10 replicates. Jamesport was a replicate of Millstone 3, which 11 was just recently licensed. And Marble Hill would have been a 12 replicate of the Byron-Braidwood design.
13 CHAIRMAN PALLADINO: What was it?
14 MR. MIRAGLIA: Jamesport. Long Island Lighting and ,
15 Power.
16 May I have the next slide.
17 [ Slide.]
18 As I said, in developing the Staff proposal for the 19 policy statement that is now before you, we considered the 20 Severe Accident Policy Statement requirements, and the l 21 legislation.
22 And the elements that have been folded into this 23 policy statement that is different from the 1978 policy 24 statement reflect those requirements that are in the Severe 25 Accident Policy Statement that I discussed earlier.
.. - . =_ _ - = - .
.- .e 29 1 Clearly, the design certification option, which is
~
_ 2 consistent with the legislation, is there, which is a new 3 element. Also, there is the threshold for modifying the 4 design of the standard plant. Clearly, the proposed policy 5 statement recognizes'the new backfitting considerations in the 6 rules, and that is clearly articulated within the proposed 7 policy statement for each of the concepts.
8 This next point is a clarification of hose one would 9 reference duplicate and replicate plant designs. The 10 timeirames for review were specliied in the previous policy 11 statement, and there was some overlap that would prevent, I
! 12 guess, a replicate from being called a duplicate.
~
13 It has to do with the viewpoint of referenceability, 14 period. And what we have said is that in this policy 15 statement, rather than to have the different timeframes, we 16 have tried to clarily it by saying a replicate plant is tied 17 to the SER issuance for the initial design base plant.
- 18 And for the duplicate plant, a plant could be 19 duplicate up until the point in time as the design approval 20 for that duplicate expires. And we are saying five years.
21 The design approval is good for five years. And a plant could 23 be duplicated as long as the point of referenceability.is --
23 CHAIMMAN PALLADINO: But 11 they build one of the 1
24 plants and then come later and want to --
25 MR. MIRAGLIA: It would then become a replicate.
1 1
,, , - , - - - - - - , . , - - ,, -- , . , , , - - , - , , , - , , .-,.--.,p. ,,,,,n -,
a = ;
30 1 CHAIRMAN PALLADINO: It becomes.a replicate.
-s I
2 MR. MIRAGLIA: Right.
f 3 So..there was this confusion before as to what bin 4 it tell in. r 5 COMMISSIONER ASSELSTINE: How long is the replication .
6 period, and when does it run from? Replicate is five years ;
7 from the issuance of the SER on the base. plant. [
B COMMISSIONER ASSELSTINE: So in terms -- if you !
t 9 wanted to replicate, say, one of the SNUPPS plants, when would .
I i-10 the door close on that? 7 L
i 11 MR. MIRAGLIA: It would be five years from the base ,
[
12 plant, which I think turned out to be Calloway. [
13 COMMISSIONER ASSELSTINE: Right, j 14 CHAIRMAN PALLADINO: What part of the base plant 15 date do you pick?
16 COMMISSIONER ASSELSTINE: When they issued the SER. -
17 MR. MIRAGLIA: When we issued the SER on Calloway, f 18 which was probably back in *83. I i
l 4
19 CHAIRMAN PALLADINO: Last supplement? i I
20 MR. MIRAGLIA: I would say it would probably be ;
i . .
21 post-ACES supplement. After the Staff has completed the '
22 review, it has been to the ACHS and we considered the comments, t
23 that supplement there would be the date of referenceability for _;
I l
l 24' replication of that design. t
' t 26 COMMISSIONER-ASSELSTINE: So you can only replicate [
t i l l l r i
31 1 a SNUPPS design for three more years 11 you didn*t get in
<3 3
2 your application in two or three --
3 MR. MIRAGLIA: Two to three.
4 CHAIRMAN PALLADINO: Suppose somebody came in in the 5 sixth year --
6 MR. MIRAGLIA: But I think in this policy statement
? what we are saying is, for the transition period the Commission 8 would be saying, five years from the issuance of the policy 9 statement.
10 CHAIRMAN PALLADINO: But suppose somebody came in 11 after six years and said, I*d like to replicate it. Do they 12 get categorically tu.ned down?
' 'N 13 MR. MIRAGLIA: They wouldn*t fit the replicate plant 14 concept.
15 CHAIRMAN PALLADINO: Well, why do we have categories 16 that might not fit the needs?
17 MR. MIRAGLIA: Well, in --
18 CHAIRMAN PALLADINO: I'm just trying to understand.
19 MR. MIRAGLIA: I think the reason for the cutoit 20 date is to attain the Commission *s stated objective of going 21 towards essentially complete designs and getting fewer number, 22 and saying there is a need for this window for a period of 23 time, 24 We picked five years. The Commission could decide it 25 should be three; it could be seven; it could be ten. That
32 1 number --
the basis was to encourage them to go to the
'D 2 reference plant concept and option, and going to the
/
3 essentially complete design.
4 CHAIRMAN PALLADINO: But you are getting r L
t 5 standardization. You got another one that is the same as 6 something else that went before.
7 Now I can understand it we think it is no longer a 8 viable design because of some new feature that we feel ought l 9 to be in. That is one thing.
10 MR. MIRAGLIA: And the policy statement does
- 11 recognize that these things would have to be looked at on a .
12 case-by-case basis. Judgments would have to be reached. ;
'N 13 CHAIRMAN PALLADINO: I don *t recall any escape 14 clause that says the Commission could grant exceptions. I 15 guess maybe there is a general exemption clause. !
16 MR. STELLO: As I recall, we are going to allow an 17 extension up to five years in the future. But, in all cases I 18 they could fall back to a custom plant review and you could i 19 approve it. i 20 MR. MIRAGLIA: Just a one-time.
21 MR. STELLO: As a one-time review.
22 There is no prohibition from doing it. But, it 23 would not fall --
and you always have that case where you fall 24 outside of the standardi=ation policy statement, and you will 25 go into a custom review.
33 1 CHAIRMAN PALLADINO: Well, but 11 it is a replicate,
., 2 I don *t know why we' call it a custom. I am trying to encourage 3 replication.
4 If you let them go back and call it a custom, they S might be more inclined to say, oh, well now that I have got it 6 a custom, I will change, And I think we should be trying to 7 encourage them to stay the same.
8 MR. MIRAGLIA: I think the real basis is to encourage 9 and get to a meaningful transition to the overall objective is 10 to be along the lines as the Commissioners here discussed 11 today.
12 COMMISSIONER BERNTHAL: But the reason finally for a i
jv t f' ) 13 cutoff date is very important it seems to me.
i 14 You cut it off after some period of time, whether 15 it is five years or seven years is a matter of policy 16 decision. If you don *t do that, standardization can end up 17 being an inhibition to progress.
18 You are essentially saying that the plant you design 19 today is good enough for all time. You are not demanding that 20 there be some kind of reassessment and reappraisal at 21 intervals.
22 That, I think, is the reason we should have a cutoit 23 date.
24 MR, MIRAGLIA: And as you said clearly it is a i
l 25 policy, and that is the balance that one is trying to --
i
,.-- _ - , - - , , r- -- < - . . -
34 1 CHAIRMAN PALLADINO: What I was trying to seek, some
?)
.a 2 option whereby if the Commission thought it was a worthy thing 3 to do at a particular point in time, they have that ability to 4 do it.
5 COMMISSIONER ZECH: It seems to me we would always 6 have that option. That is never limiting.
? COMMISSIONER BERNTHAL: It i t turns out that advances 8 in reactor design have not been particularly substantial, the 9 source term research and whatnot confirms that current designs 10 are entirely adequate, then the Commission always would have 11 the option of extending --
12 MR. MIRAGLIA: With justification, that certainly
'N, 13 could be done. And that could be brought to the Commission 14 saying it is six years, but here is the basis for the 15 application within this concept. And it could be reviewed on 16 that concept.
17 COMMISSIONER BERNTHAL: Normally -- that is why I 18 feel so strongly that we have got four policy statements that i
19 interlock, and that are terribly important that they more or 20 less come out in coordination; safety goal and advanced 21 reactor policy statement fit into this business, it seems to 22 me. And it is very important that the Commission decide where i
23 it wants reactor design to go both in terms of safety and l 24 progress.
25 You know, if you just sit there with a standardised 4
~ - - - - - .- - - - a , e -- -.-
,-w~m-
35 1 plant system, we may have an inhibition to any progress
() 2 whatsoever in terms of true safety characteristics.
3 CHAIRMAN PALLADINO: I wasn't trying to inhibit, 4 just trying to see what degree of flexibility you had
(
5 envisioned in your thinking.
6 MR. MIRAGLIA: With respect to another element, the
? policy statement that is now before you is consistent with the 8 proposed legislation with respect to tees.
9 In order for the policy statement to actually 10 implement that, there needs to be change in the legislation.
11 Without that, we would have to go back to the previous position 12 on fees The tee provision here is one, to be an inducement
/ 13 that their toes could be waived consistent with the 14 standardization legislation. But, it would require a 15 legislative change in order to enact that.
16 CHAIRMAN PALLADINO: I see. We can't --
< 17 MR. MIRAGLIA: Without the legislation we would have 18 to modify th:' trovision to be consistent with the existing 19 fee schedules.
20 CHAIRMAN PALLADINO: Okay.
21 MR. MIRAGLIA: Which would, I guess, not have the 22 same degree of inducement. There would be some partial waiving 23 of fees depending upon the number of applications that are 24 going to reference the specific designs.
25 COMMISSIONER ASSELSTINE: How do you tigure that out i
3G 1 as a practical matter, Jim? Here you have got a reference
-n
( _) 2 design, you know it costs you-X amount of dollars to do the 3 review and approve the design.
4 After that, how do you decide how to apportion those 5 costs? You don't know in advance whether there is going to be 6 one user, two users, five users or twenty users.
7 MR. MIRAGLIA: I will have Cecil -- Cecil has been 8 involved in making those determinations on the last few, so I 9 will let him respond to that.
10 MR. THOMAS: That's a good question. I'm not sure 11 we really have the answer.
12 The fee schedule that was in ettect prior to 1984 T'N 13 assumed there would be five users. And you would allocate 20 v
14 percent to each of the tive as they came in.
15 We got into this situation a little bit because of 16 the proposed legislation. The language is almost identical.
17 And the Office of Administration has pointed out in your paper 18 that this is something that we have to come to grips with 19 somehow.
20 Not only that question, but if no one references it, 21 how we are authorised to go back and collect retroactive toes 22 from an applicant.
1 23 CHAIRMAN PALLADINO: But another way is te have the 24 designer pay the fee up trent, and then collect from the 25 customers themselves. I expect this is not a major fraction l
l
. . . . ~ . _ . -. .-. - ..
4 .
37 1 of the. costs he is going to incur anyhow. However, I T'
is} : .
2 understand the inducement.
3 MR. THOMAS: However, within the current fee 4 structure, it is number of millions of dollars. Yes, in i 5 relationship'to the up front commitment of the design, it is a 6 small point.
7 COMMISSIONER BERNTHAL: I just wanted to compliment i
1 8 you on what I thought was some creative thinking, and thinking 9 that exhibited a good deal of foresight in the suggestions you j 10 have made here in design fees allocations and whatnot.
l 11 One of the hangups that I had had at least up to 12 this point was wondering how in the world you get this process 13 started when nobody seems willing to step forward right now j 14 and ask for design certification.
15 I hope that the approach you are suggesting here 16 can stick. I am a little worried that it may not. But, I 17 think that it will get the ball-rolling. Because, i t '!
18 understand what you are saying here, you are suggesting that 19 the NRC proceed with design certification. But that the 20 burden then of coming up with a design that is salable on the 7
21 market in the end, at the end of ten years, I guess, falls on
- 22 the vendor. ,
-f >
23 I think it is a good idea It is a creative 24 approach. I compliment you on the concept.
i
- 25 MR. MIRAGLIA
- It is a very small carrot, as the t
._. . y. . . - ..
38 r.
1 Chairman points o st .
).
.s 2 MR. STELLO: The industry brought up the issue of f~ .
+,
who would come'iorward with certification.
3 The ma}or problem 4 is, where,are they going to g4t the funds to support the 5 design ettort r.e c e s s a r y , which are in the many, many millions y
t of dollars. And that,is going to be the bigger problems in 7 terms of an incentive to come iorward.
COMMISSIONER BERNTHAL:
8 But the -- let me see 11 I 9' understand'right here. My thinking and my presumption was i ,
11 tbst the three vendors already have a design that is olose to i
li something that they could consider coming in for design-lig cert 11'acation approval on-at thi4' point.
~'
13 Is that true) i 14 And that that is'a,510 eillion, roughly, proposition t
1: ; -
15 or something like that?'
a
- ~.., O' \
3 16 MR. MIMAOLIA: I think that is a separate question, 9
th the fee question, isn*(*it?
18 MR. THOMAS: Yes.
- t. : w 19 MR. MIRAGLIA: For going forward with the design
.. , , .> m
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20 certification.
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21 3 MR. THOMAS: It can be related. I don't think we
,. 22 have 4 t/ d r e s s o a the fees associated with the certification
)
23 pg5ce')Ak Only through the design approval process right now.
t g
. 24 N MR. STELLO: They already have s it.
. v
- 2d ' . CGMMI SSIONER BERRi t' AL : I s e!v g, only the final N
A
,.. 1
- ., . . . - , , . , -. , - . ~ . - - , - - - ,
39 1 design approval process. And you haven *t considered applying q 2 that to design certification?
s j 3 MR. MIRAGLIA: Well, I think 11 one looks at the fee 4 structure, there is a cap on the fee. And dependent upon 3 whether you start the fee structure all over for the design 6 certification. I don *t know if that is clear.
7 MR. THOMAS: We do intend for the proposal here to 8 apply to the certification process. It is just that no tees 9 have'been established for the certification process.
10 COMMISSIONER BERNTHAL: Well then I will get to my 11 question. What kind of money are we talking about here for a 12 design certification?
13 MR. THOMAS: We are not really sure yet because we
{'
14 haven *t really come to grips with what --
15 COMMISSIONER BERNTHAL: Give me a guess.
16 MR. THOMAS: Well, 11 you assume the order of a 17 year, you are probably talking about a half million dollars or 18 so.
19 COMMISSIONER BERNTHAL: A year, with hearings and 20 everything?
21 MR. THOMAS: Okay, half a million dollars a year.
22 The fee for an FDA is the order of what, a million
- 23 and a halt dollars. The certification would be same order of i
j 24 magnitude, in addition.
25 COMMISSIONER BERNTHAL: That sounds low to me.
I
.' l
) 40 3
1 I had been using in my own mind the number s10
.o ..
,) 2 million for a complete, design certification. And it was that 3 kind of number that was daunting
( --
I assume was somewhat 4 daunting to the vendors. But, whatever it is --
5 CHAIRMAN PALLADINO: T e legal fees would begin to a
6 approach that $ 5 0 0 , 0 L! O a year. '
't
, \
7 Excuse me . , ,
8 MR. MIRAGLIA: Also, tho' proposed policy indicates 9 that f i.n a l design approvals, design certificapions are 10 renewable, and that the PDAs would be renewable 11 good cause 11 were shown as to perhaps why there was a delay in getting into i t i
12 the itna1 design process.
I-3
- 13 And so that element has been incorporated into that.
\-- ;
14 CHNIRMAN PALLADINO: Could you refresh my memory.
15 Why do we have PDAs? What are we approving? Is it a 16 preliminary approval of a design, or is approval of a 17 preliminary design?
18 MR. MIRAGLIA: It would be a design approval that
't 19 would allow,'perhaps, construction to go forward.
- 20 CHAIRMAN PALLADINO
- Answer my question. Is it i
- 21. . a p p r o v a 'l o f a preiiminary design, or is it preliminary approval
'22 of a.-- f
's
- 23 MR. MIRAGLIA
- It would be consistent with the level l.
24 of design information necessary to issue a CPU, PS AL: 8 type m94 25 information, s
i
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l
, . - , + - - . . . - , , , - . - - -. , . , - , - , . , , -
41 1 MR. STELLO: The concept is, 11 someone were to
-)j 2 submit a CP and you had to review this information, that 3 information could be pulled out and put in as a PDA application 4 for that portion of the plant.
5 Then that level of information which you would 6 normally have available for CP review process could then be 7 approved generically. You wouldn*t have to do that on all 8 these cps.
9 The same concept then for a final design approval 10 with the information you normally need for that final design 11 in a final safety analysis report could be again gleaned out, 12 submitted as a separate package, and then you would not need 13 te review that in these individual cases.
14 And it saves, both for us and for the vendors, a 15 great deal of effort from having to rereview that for each 16 case because you can do it once generically. So when you have 17 then the PDA it means that you don *t have to have that 18 rereviewed for each construction permit, or the FDA for each 19 FSAR.
20 CHAIRMAN PALLADINO: So far as the individual 21 performance is concerned *f 22 MR. STELLO: That*s correct. That*s the reason and 23 the concept.
24 COMMISSIONER ASSELSTINE: There is nothing wrong
,C i
25 with the FDA concept.
i l
i 42 1 I guess where I have ditticulty though is saying
,, 2 that the LPDA is going to be good enough then to start building 3 a plant. Then it seems to me you are repeating the mistakes 4 that we made in the past, starting to build plants with lots of 5 issues still open to be resolved by the time you get that FDA 6 type or FDA level of information. It means you are going to 7 end up with lots of changes to the plant.
8 CHAIRMAN PALLADINO: I was taking the view that that 9 PDA may be useful to licensing process. But it isn't i
10 conducive, necessarily conducive to standardization.
11 COMMISSIONER ASSELSTINE: Yes.
12 CHAIRMAN PALLADINO: I'm not sure it is necessarily 13 a part of standardization --
14 MR. MIRAGLIA: PDAs would have to be very well 15 conditioned as to what the items are that are still open for 16 review, 17 COMMISSIONER BERNTHAL: I have to confess I am not 18 sure that I am not getting more confused on this alphabet 19 soup, rather than less confused.
20 My naive idea, apparently naive, was that PDA, FDA 21 were preliminary steps leading up to what we area really after 22 here, which was design certification. A kind of license of 23 powerworthiness for a power plant with all the specifications, 24 11 not the nameplate for the essential components of a power i -
25 plant.
l l
- l. . _- .
~ _ __ _
43 1 That was what I thought we were talking about here.
7m j 2 I thought PDA and FDA were sort of steps along the way that 1
3 have no direct applicability to what the Commission's view of 4 standardisation really is.
5 Am I off on a tangent?
6 COMMISSIONER ASSELSTINE: I think that is fair.
7 MR. THOMAS: In the past, the FDA and FDA were 8 analogous to a CF and OL respectively. They were approval, 9 preliminary design approval of a final design.
10 COMMISSIONER ASSELSTINE: Which in themselves, at 11 least the FDA level in the past would permit the start of 12 construction of the plant.
13 I think what Fred is talking about, is saying now we 14 are going to have a process that leads to a reference design.
15 The reference design is then what triggers the ability to come
, 16 in and ask for authority to start building a plant.
17 PDA and FDA may be intermediate steps along the way 18 to achieving the reference design. But, it is now the 19 reference design that becomes the-trigger for the ability to 20 come in and ask for approval to start construction.
21 CHAIRMAN PALLADINO: That's why I was saying they 22 may be useful in the licensing process, but I non't think they 23 are a necessary part of the standardization process.
24 MR. MIRAGLIA: The policy statement doesn't have
\w 25 that kind of language. But that is certainly something that l
l
. =
l l
44 I can be considered.
_' 2 CHAIRMAN PALLADINO: I think the fewer of these 3 things that we confuse the policy statement with, the better 4 it will be. We may want a supplement that says in addition 5 there are other things going on, and here it explains what 6 they mean.
7 COMMISSIONER ASSELSTINE: It gets awfully convoluted 8 when you throw all that stuff into the pot.
9 COMMISSIONER BERNTHAL: I agree. I think it doesn't 10 matter so much wnat we call the standardized plant concept.
11 What matters, really, is how we go about doing this.
12 And driving the process to achieving a design 13 certification -- and I wi1Y use that term because I thought 14 that is what we were driving for -- in the short term as soon 15 as possible, so this Commission is on record with whatever 16 financing arrangement we can work out, that we are on record 17 that our part of this bargain is completed. Now it is up to 18 you people out there.
19 I thought that is where we were heading. And I 20 would hope that we don't confuse it too much with the arcane 21 terminology that relates back to an earlier time. I am 22 concerned.
23 MR. MIRAGLIA: May I have the next slide, please?
24 [ Slide.3 25 MR. MIRAGLIA: As Mr. Stello had indicated in
e 45 1 discussions with the industry, it was clear. that some period 2 of transition would be necessary in implementing the 3 standardization policy, and the industry view that was 4 articulated, they felt in the near term the most applicable 5 concept that is likely to be used in the near term would be 6 the replication concept. And in the proposed policy statement 7 we recognize the need for this transition, and we have built 8 into the proposed policy statement a replication period that 9 would extend five years from the date of the issuance of the 10 policy statement, that we would look at each of the severe 11 accident policy statement considerations to determine whether l
l 12 there should be any reliet from those based on good cause
~'
13 shown and good evaluations indicating the degree that those 14 conditions should be complied with.
15 We have put the additional constraint of the plants 16 that were reviewed against the NUREG 0800, which is the 17 version of the revised standard review plan that incorporated 18 all the TMI requiraments, and that was July '82 or '83,
'19 I believe. That plant design could be replicated at any 20 site. It it was not reviewed to that version of the SRP, it 21 could be replicated at the same site by the same operator, and 22 in addition would have to be supported by the design 23 performance and operating history of that facility as a 24 consideration of a plant for replication.
a.y 25 It it was a plant. that has run well and the design
e
- 46 1 is shown to be proven and has a gooo operating history, we
. ~ ,
j 2 would consider replication of that same design, operated by 3 the same designer at the same site, as a point of departure 4 for a transition.
5 COMMISSIONER ASSELSTINE: Why do you have any 6 site up there?
? MR. MIRAGLIA: This would be on a newer design 8 plant against the most current version of the SRP, would be at 9 any site.
10 COMMISSIONER BERNTHAL: But the replica concept 11 is a transitional concept, I guess, isn't it? That's how we 12 deal vii t h wha t we've got out there right now.
/ 13 MR. MIRAGLIA: And we are talking about the five 14 year, we are saying five years from this policy statement.
15 Whether that should be five, or shorter or longer, is really a 16 policy decision. We are trying to balance the innovations and 17 the technology versus what we would require.
18 COMMISSIONER BERNTHAL: So the Commission would 19 make a decision that for some limited period of time during 20 which it appears, we aren't going to have any applications, 21 anyway, we are willing to buy replication, let's say, of a 22 SNUPPS plant. But beyond then, we expect something different 23 and better.
24 COMMISSIONER ASSELSTINE: This non NUREG 0800, w
25 though, would be broader than that? That could be an older
47 1 plant?
,. s 2 MR. MIRAGLIA: It could be, and I'm not sure whether 3 St. Lucie is an 0800 plant or not, but as an example, you can 4 have a St. Lucie 3 at the same site, 11 it was an older plant 5 MR. STELLO: Let me get to Commissioner Bernthal's 6 question first.
7 The policy statement recognizes that that is the 8 Commission's desire to achieve this trua certification 9 process. But what it fails to do is identify when you can get 10 there.
11 I don't think you can answer in terms -- in a 12 quantitative sense -- time. I think that is very, very
/'; 13 difficult to do, and I don't know that we can make the
- n. -
14 judgment. We offer no judgment except to say that*s the 15 direction that the Commission wants to go.
16 CCMMISSIONER BERNTHAL: You mean how soon we can have 17 our first design certification, first license to manufacture, 18 if you will? Is that what you're saying, we can't --
4 19 MR. STELLO: No, the latter part of the question, '
20 when can we say no more replication-or duplication, we're 21 done, we won't permit it any more When do you stop that? I 22 don't think we know when you can make the judgment that that 23 would no longer be permitted.
24 I don't know how to do that, All we say i s ,- its a
25 intent is to move in that direction, but I don't know.
f .- e r.- ,v -,,,.e. , .. . , - . . . ., ,e ,
48 1 -Let me see 11 I can give a simpler answer. NUREG 2 0800, that's in a sense a benchmark in time. Here were all 3 the requirements laid out comprehensively in NOREG 0800 in, I 4 think it was, 83 and then it says from then on, these are a 5 citterent class of plants from those that were before then.
6 The ones before, 11 you want to build one at the same site, 7 same operator, we don *i think you ought to discourage that 11 8 it's a really good plant and it's got a good operating 9 history. You might want to consider that option.
10 COMMISSIONER ASSELSTINE: Even 11 a plant itself is 11 10 years old?
12 MR, STELLO: No, there's a time tag to it. It's
' N 13 tied to five years of the date of the SER, so there*s a time 14 tag in addition to it.
15 MR. MIRAGLIA: I think I also want to clarity a 16 point and make sure Commissioner Bernthal doesn't think that 17 after five years the replication concept as currently 18 constructed in the policy standard -- replication concept 19 would still be an available concept. It is not a sunset 20 provision for that as currently written. I got the sense that 21 that's what you --
22 MR. STELLO: That's a question I am just dealing 23 with. I said we are only dealing with the policy.
24 CHAIRMAN PALLADINO: I'm ccafused Your answer was 25 yes, it is a sunset provision.
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49 1 MR. STELLO.: Only in terms of the Commission's 2 desire, but not in terms of an actual date. We don't know how 3 to put a date in.
4 CHAIRMAN PALLADINO: That was my problem.
5 MR. STELLO: I don't know how to pick a date, so we 6 simply said --
7 CHAIRMAN PALLADINO: You said five years.
8 MR. STELLO: What we simply said was that we want, 9 you, the Commission, wants in the future to achieve the true 10 concept of standardization in terms of the certification 11 process. That's where you'd like to get to, but you don *t 12 know how, we don't know how to tell you when.
13 COMMISSIONER BERNTHAL: I think the date will be 14 determined as time goes on by broad evolution and advance in 15 designs. You know, the advanced reactor policy statement is 16 setting out in a very broad sense, it seems to me, the 17 directions that we think design ought to go.
18 Now how soon you achieve that, I think, finally will 4
- 19. determine how soon you say no more replication, because we 20 think that what is out there, perhaps what other countries are 21 already building, is a significant advance over designs that 22 we have had in the past and we are not going to replicate 23 those any more. There are better things now.
24 CHAIRMAN PALLADINO: I'm a little confused.
25 COMMISSIONER BERNTHAL: That's a rolling judgment
9 *
$0 I we'll have to make.
2 CHAIRMAN PALLADINO: I raised the question because 1 3 was worried that we were setting a timeirame to limit t 4 replication.
5 MR. STELLO: No.
6 CHAIRMAN PALLADINO: That*s why I raised my r
? question. When you say, well, we're going to allow replication !
8 for five years after the policy statement -- which is fine as a ,
L 9 target, and I wanted to make sure that we had a way out, 11 10 events showed the situation to be different from the way we l i
11 perceive it now. And now you are saying, well, you don *t want I 12 to put the five years, 11 I understand you, so tell me what it [
l 13 is again that you are telling me.
l 14 MR. MIRAGLIA: For a plant that*s licensed -- 11 we 1
15 had -- let*s assume five years when the policy statement is i f
16 up, you could still replicate a plant that was built the year 17 before.
18 In other words, five years from now would be 1990.
19 It we licensed a plant in *89, that plant as currently 20 construed would still be able to be replicated five years past 21 that date.
- i 22 CHAIRMAN PALLADINO: Then what does the five year --
23 MR. MIRAGLIA: This extension here of saying five 24 years from the policy statement is-recognition that there have '
i 25 been a number of plants recently licensed that we would be i
. , - . - . ~
51 1 -saying their term of referenceability that would be s
2 foreshortened.
3 COMMISSIONER BERNTHAL: What you are really saying, 4 then, is every time the Commission licensed a plant, it would 5 not only be licensing a plant, it would be acting on the 6 standardization policy to extend the referenceability by five
? years?
8 CHAIRMAN PALLADINO: That is the way it sounds.
9 COMMISSIONER BERNTHAL: That's very interesting.
10 I'm not sure --
11 CHAIRMAN PALLADINO: That's why I was confused. I 12 wish you would clarity it in your writing.
/^ 13 MR. THOMAS: Could I just take a quick stab at maybe 14 standing back and looking at the big picture? I found this 15 very helpful to understand.
16 I think it is useful to look at standardization, the 17 tour options that we have in our policy statement, from the 18 standpoint of who the participants are likely to be, 19 Replication, duplication are largely for the benefit of the 20 utilities. The utilities don't need a vendor in that process.
21 A utility could decide to builo a plant just like another one 22 that a previous utility built.
23 The reference design option is aimed primarily at 24 the vendors. The vendors have been the AEs and the vendors 25 have made use of that, although there is nothing that would
d2 1 preclude a utility from having its own design certified.
2 COMMISSIONER ASSELSTINE: They are not going to do 3 that as a practical matter.
4- MR. THOMAS: Right. But the important thing is that 5 for the duplicate and replicate concepts, we want to -- we 6 feel that there is a useful role to be played even at the 7 intermediate term there, and for replication we have allowed a 6 plant to be replicated, not automatically but a proposed 9 application that would replicate a previous plant would have 10 to undergo a qualification review. The Statt would have to 11 make a judgment as to whether or not the base plant is 12 appropriate to be replicated.
( 13 So it is not an automatic -- once you issue an OL, 14 it is not an automatic invitation-for someone to lock onto it 15 for five years.
16 COMMISSIONER BERNTHAL: I wouldn't say five years at 17 all, because it sounds to me like an open-ended possibility 18 that you will be given permission to replicate a plant.
19 MR. THOMAS: It's possible. The five years was 20 really to accommodate -- to keep it relatively current. You 21 would be dealing with regulations, regulatory --
22 MR. MIRAGLIA: It was our desire to replicate within 23 that timeframe, but it would be a conscious decision, "Yes, 24 this plant should be replicated."
D 25 COMMISSIONER BERNTHAL: But as the Chairman says,
i l
$3 1 what 11 somebody comes in six years later and says, "We*d like
._ ' 2 to replicate that plant." Do you say, "No, I'm sorry,-the 3 curtain tell last year?
4 MR. MIRAGLIA: I think you could make that kind of 5 decision again on a case-by-case basis.
6 COMMISSIONER ASSELSTINE: When dID the NUREG 0800
? plants start? After St. Lucie?
8 MR. MIRAGLIA: Well --
9 COMMISSIONER ASSELSTINE: Or do they vary?
10 MR. MIRAGLIA: I'm not sure which the first plant 11 was that it was conducted entirely under that. The issuance 12 was -- I guess it was in July of -- it's either '82 or '83, 13 I'm not sure when the issuance of that was. So plants reviewed 14 -- some of the plants, even though they were licensed 15 afterward, may have been done under a different revision 16 because -- .
17 CHAIRMAN PALLADINO: How about checking that? It is 18 important that we have accurate information.
19 COMMISSIONER BERNTHAL: I think we are getting hung 20 up on this replicate and duplicate business. I think those 21 are likely to be, as a practical matter, likely to be a very 22 small number of plants that could come along in the early 23 1990s, perhaps. But I have just got to believe by the 24 mid-1990s and beyond when you may see a major construction 25 program of some kind that those are going to be based on i
I i
54 1 something that is sitting here today that we would like to be 2 certified designs. It seems to me that is where we ought to 3 focus.
4 CHAIRMAN PALLADINO: I have a lot of problem with 5 the replicate and duplicate. At times I think it is a 6 distinction without a difference, and then there are times
? when I say but we are always going to have replicate and 8 duplicate. That s what we want. We want standardization 9 which means you duplicate or rsplicate these plants. So I get 10 confused by introducing those terms, especially when I can 11 replicate at the same site at which I can duplicate. It 12 depends on the timing, and I suggest you give a little more 13 thougnt to the names.
14 Maybe these were acceptable names in the past, but 15 we are trying to achieve replication and duplication, and 16 to say we are going to turn it off in five years gives me a 17 little bit of a problem.
18 MR. STELLO: There are two concepts that need to be 19 kept very, very clear:
20 First, is how long would you consider allowing 21 replication of plants, plants that are not certified? Answer:
22 We don't know.
23 That concept, how long will you keep it? Now,
( 24 question --
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25 CHAIRMAN PALLADINO: When I get a standard design, I i
l
$5 l I
1 have to replicate them --
2 MR. STELLO: That's a certified design, and you do 3 those. That's different.
4 CHAIRMAN PALLADINO: That's not replicate.
$ MR. STELLO: No.
O CHAIRMAN PALLADINO: I can't use the word I'm going
? to replicate standard design?
8 MR. STELLO: No, because the Commission's policy 9 statement ditierentiates between those.
10 Now for a plant, a particular plant, Plant X, how 11 long would you allow that plant to be replicated? On that you 12 can put a time estimate, because you don't want this plant 13 replicated for the next 25 years. You will have other plants, 14 hopefully, that you can look for, so you put in a period of 15 time and say you are allowed to replicate this plant for this 16 period of time.
17 But the whole concept of replication continues until 18 we evolve into this true process of certification. How long
- 19 will that take? I don't know. But if you look at any of the 20 advanced reactor concept, it is very unlikely that you would 21 over even have one in operation, built in the next 15 years.
22 COMMISSIONER BERNTHAL: The point is replication and 23 duplication have literally nothing to do with standardization i 24 as the Commission envisions it. I think that is why it is a i
i
- 25 distraction, almost, to be so concerned right now about that I
l l
56 1 transition possibility.
2 MR. MIRAGLIA: It's a standardization in a different 3 and more limited sense than having --
4 CHAIRMAN PALLADINO: Maybe the actuality that we are 5 going to face --
e MR. STELLO: Again, let me get back to what I said.
7 The need for this kind of complexity is a result of what the 8 industry has suggested they want in terms of a market, what 9 they are going to buy.
10 Now 11 that is not correct, then you clearly don't 11 need those options, and I am not so sure that we know what the 12 market is, 11 there is anybody that knows what the market is, 13 except the best advice I think you can get in terms of what 14 the market would be are the people who will buy them.
15 It -this is what they are telling us, then should the 16 Commission say, "But I am not going to provide for that 17 capability to build plants," 11 this is what they tell you 18 they want? It clearly -- the Commission has the authority to 19 say no.
20 COMMISSIONER BERNTHAL: We are not suggesting that.
21 What I am saying is that we have spent a lot of time, all of 22 us, in the last few years, talking about standardization. The 23 duplication and replication, to be sure, are an essential i 24- practical feature of whatever policy we come up with, but it 1
i.
25 is not saying that we want our Sizewell II, 11 you will, in l
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57 1 this-country, and that's a design-certified plant. That's 2 what the Commission has in mind for the mid-1990s. That's all 3 that I'm saying, and I think this other stuti in here does 4 tend to confuse the issue.
5 That is not to say it needs to be all thrown out.
6 It's not the emphasis, though, of the Commission's policy, it 7 seems to me.
8 COMMISSIONER ASSELSTINE: It does seem to me that 9 what we ought to do is maybe have a little better fix on how 10 this all tits together in terms of what the markets are likely 11 to be over the next say 20 years.
12 As I recall the EPHI discussion, when we had that, 13 you know, when Saul Burstein and the others were here, they 14 seemed to be saying that the industry looks towards ordering 4
15 plants in the beginning of the early '90s, and they are really 16 looking to somewhat improved designs; not perhaps radical 17 departures from light water reactor technology, but advances 18 in those designs of the sort that Westinghouse and GE and I 19 guess Combustion as well all seem to be working on at the 20 moment, or perhaps even 'a step beyond that.
21 Then you get into what you do in the interim and how 22 likely is it that utilities will be ordering additional plants 23 between now and the early 1990s, and what their interest it.
24 I would almost like to see a survey.of utility CEOs, write 25 them and'ask them, "Do you envision ordering another nuclear l
l 1
58 1 power plant between now and the early 1990s? And 11 so, what
.3 2 do you envision ordering? And do you believe that it is 3 essential to retain concepts such as would you build another 4 plant like the ones, a replicate or a duplicate of the ones 5 that are now coming into operation or that have been in 6 operation? And do you think that it's essential to maintain 7 that option between now and say 1991, 1992?"
8 The sense I get is that the vendors would like to 9 retain that option, but that there is considerably less 10 enthusiasm for it or interest among the utilities themselves, 11 other than perhaps something to assist in reactivating some of 12 the plants e. hat have been deterred.
13 Maybe I am wrong about that, but I haven't heard a 14 lot of utility executives that say, "Yes, I want to build 15 another plant" --
16 MR. STELLO: One way I think you c3n put the issue 17 to bed -- and I was going to suggest it at the end of the 18 meeting. I will suggest it now. The Commission might want to 19 consider, since we have an industry group called NUMARC, 20 ostensibly, with the senior representatives who would be 21 intimate in making a decision on new plants, send it to 22 them and ask them -- not to dratt or suggest a modifications 23 policy -- but the simple question, "Does this policy statement
- 24 allow the kinds of options that you foresee necessary, in your l
l 25 view, what you would do if you were to in-fact order another l
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- 59 1 plant," and get an answer from NUMARC.
2 CHAIRMAN PALLADINO: That may be one approach. I 3 think some of the answers to the questions that Jim has raised 4 the AIF has explored from time to time. I don't know if they 5 have been exactly the way you have indicated.
6 I was thinking we ought to ask the industry group to 7 make such surveys, and your suggestion on NUMARC --
8 MR. STELLO: NUMARC is clearly going to be -- they 9 represent the people who buy them.
10 COMMISSIONER ASSELSTINE: Clearly I get very 11 different perceptions from the people who sell them as opposed 12 to the people who buy them. Vendors come through and they 13 say, "You know, we think it is really realistic that somebody 14 could come in and they*11 order another SNUPPS plant or order 15 another GESSAR plant or System 80 plant. We think that's 16 really realistic."
17 Ycu talk to the utilities -- and at least I
- 18. personally don't get the sense that anybody is actively 19 considering that, at least between now and the time when the 20 more advanced or improved generation of light water reactors 21 might well be available and viable options in the early 22 1990s. Maybe I am wrong about that, but it would be 23 interesting to know that.
24 MR. MIRAGLIA: I think the AIF letter tried to 25 capture and balance that in here.
e '
60 1 COMMISSIONER ASSELSTINE: The problem with AIF is s.
2 AIF represents the full spectrum of the industry, and what you
.3 may be seeing is the vendor perceptions, who aren't the people 4 who are going to be buying them.
5 CGMMISSIONER BERNTHAL: We do have a request from 6 AIF to come in and speak to us --
? CHAIRMAN PALLADINO: I'll bring that up at the 8 agenda planning. We had a conversation on that.
9 COMMISSIONER ZECH: I suggest we let them finish.
10 CHAIRMAN PALLADINO: Yes, why don't we let them 11 finish. I do want to make one point on my question, by 12 clarifying duplicate and replicate I wasn't saying throw them 13 out. I think that may be the realistic future, at least for 14 the next five to 10 years.
15 MR. STELLO: I think that is true.
16 CHAIRMAN PALLADINO: But clarifying them would help.
17 Okay, why don't you go ahead.
18 MR. MIRAGLIA: May I have the last slide, please.
19 [ Slide.]
20 The last slide is a brief summary of the difference 21 between the Stati proposal that is before you, as opposed to 22 what was in the AIF letter. In the issue of terms of approval, 23 the Staff is recommending a 10-year term of approval for a 24 design certification, and for the other concepts a five-year 25 term of approval, and the-AIF position was all concepts should
, e-6b 1 be 10 years.
m Again, the reason for the Stati distinction again is 3 to say there is an -- encourage the need to go to design 4 certification process, and we thought there should be that 5 difference. Again, should it be three, five, seven is a 6 matter perhaps of policy. We are suggesting five.
? With respect to the renewal of a preliminary design 8 application, we said only for good cause. Again, I think 9 while we have not linked it in perhaps the terms that 10 Commissioner Bernthal was thinking, we feel that you should 11 renew the PDA if there is good cause, 11 we are heading 12 tovards the FDA, it we are heading towards design 13 certification, and we should not just allow for automatic 14 renewals.
15 The AIF position would be that timely application 16 for renewal should be considered, and we are saying for cause, 17 for good cause.
18 The level of design information, for design 19 certification, and final design approvals, the Stait's thinking 20 is along the lines we need information-equivalent to final 21- design FSAR information. The dialogue with AIF, the indication 22 is something in between, maybe, or less than that might be 23 acceptable, i 24 I think AIF recognizes there is a need for both 25 industry and the Staff to really come to grips with what i
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62 1 exactly the level of design information is needed to fulfill m
2 the terms of requirements.
3 CHAIRMAN PALLADINO: This is a fundamental question, 4 and I can't understand why they want less than the FSAR for 5 final design approval, or design certification.
6 As a matter of fact, in my own thinking, I would 7 expect more than the FSAR.
8 MR. MIRAGLIA: The concern being essentially in 9 order to have a complete design, it*s a substantial commitment 10 of engineering and design resources. It's money. Certainly 11 11 one talks in terms of near-term options and longer-term 12 options, meeting that on a design that's out there and been 13 approved, on which an FSAR has been prepared, is more likely 14 than one that's already been behind one, as opposed to one 15 we're starting with a clean sheet of paper. *-
16 So I think it is reflective of those kinds of 17 concerns.
18 COMMISSIONER ASSELSTINE: Again the attention of 19 different parts of the industry, it's money'by the vendor to 20 put together a more complete design, but the quid pro quo for 21 that is certainty by the customer in terms of knowing that 22 what he has got really has the final approval isn't going to 23 he tinkered with later on, or throughout the process.
24 MR. STELLO: Frank, I think I recall one other 25 consideration that stands out. One of the other concerns they l
l l
63 1 'had was when you put in an FSAR, you can say you bought a 2 Byron Jackson pump, and this is it, right here. When you 3 start to do that design certification and you start to try to 4 incorporate that level of detail, they're concerned about 5 running into the antitrust problems, and there they are 6 looking for ways in which they would have to back away from 7 that kind of information.
8 In the meeting that I was at, I just have a vivid 9 recollection that that was their bigger concern in terms of 10 really trying to lay out the kinds of information you have 11 available* in the FSAR, because i t' e x'i s t s , it's here, and you 12 can identity it.
13 CHAIRMAN PALLADINO: How do automobile manufacturers 14 get around the antitrust problem?
15 MR. STELLO: I don't know.
16 CHAIRMAN PALLADINO: You get this run of cars and 17 it*s got the same generator on it, car after car. What de 18 they do that we can't do? Now perhaps they manufacture it 19 themselves so that they don *t have to go out and bid them.
20 MR. STELLO: I don't -- maybe Jim can help us. I 21 don *t know enough.
23 CHAIRMAN PALLADINO: Neither do I.
23 MR. STELLO: As I understand the way it's expressed, 24 11 you start to give attributes and characteristics such that 25 you will prescribe a particular manufacturing component in
04 1 what you embody in the regulations for design certification, ,
-s 2 then that cr.uses us to have a problem with antitrust, as I 3 understand it.
4 CHAIRMAN PALLADINO: If we start to do it?
5 MR. STELLO: No, when we get to design certification 6 and putting it in our rules, we are doing it.
? COMMISSIONER ASSELSTINE: That*s right.
8 MR. STELLO: And that*s why it is considered a 9 problem. Obviously if you have FSAR and we approve it, we s:
10 haven *t in any.way limited that to one manufacturer. The next 11 FSAR could have a different one.
12 CHAIRMAN PALLADINO: We might want our legal people 13 to --
14 MR. STELLO: I*ve just given you my understanding.
15 CHAIRMAN PALLADINO: Let me finish the sentence. I 16 do think we ought to have our legal people examine this issue, 17 and to give us a report on the constraints under which we 18 work.
19 COMMISSIONER ASSELSTINE: I think that*s a good 20 idea, but I also think there may ce a way around the problem.
21 We also ought to look at this; to the extent you can specify l 22 performance characteristics, it doesn*t necessarily tie you to i
23 a specific manufacturer or a specific nameplate component, as i
24 Fred mentioned. But this is the performance we expect out of 25 the pump that we are going to use over here in a way that l
OS 1 gives you the information you need to resolve any design or 2 safety questions that may be involved. That doesn't get you 3 to a level of detail of saying, as they do in the FSAR, once 4 you've purchased a pump, this is a Byron Jackson pump Model X.
5 MR. STELLO: That is a good proposal.
6 CHAIRMAN PALLADINO: That*s a good idea.
7 CCMMISSIONER BERNTHAL: It's an interesting sideline, 8 it seems to me, that the more deeply you get into specifying 9 oven components, characteristics, as opposed to nameplate, of 10 course, the more deeply you get into that, the more deeply we 11 are going to get as an agency into vendor certification. Tom 12 isn't here. And that would be the vendor inspection.
13 COMMISSIONER ASSELSTINE: The same problem exists in 14 the airline industry. The FAA certifies airplane designs.
15 There has to be a way to deal with that problem, to identity 16 the level of information you need to resolve all the safety 17 issues without getting into antitrust difficulties on the 18 specific component. I'm sure Boeing or McDonnell-Douglass 19 purchases components from a range of suppliers to put on their 20 airplanes. They don *t manufacture every piece in a plane.
21 There has to be a way to resolve the design issues, to get 22 that certification of a plane. But that doesn't run you into 23 antitrust problems. There ought to be a way around it 24 MR. MIRAGLIA: All we are trying to identity here is 25 that this is an issue, and we use the word " e q u i =r a l e n t . " They
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? COMMISSIONER BERNTHAL: Do they certify vendors or 8 do they --
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9 [' COMMISS'lpNER ASSELSTINE: I t' h i n k they get into
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15 approved final design is. subject to litigation," this is under i ~
16 final design approval.} sand individual licensing proceedings i ss
., '1/ s on these a p p l i c a t i on s .*M 'Do you mean 11 you'have an FDA, you
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21 MR. M,'1 R A G L I A : The final design approval that is p, ,
22 being described there si s the design, prior to going to the s *
. N 4 l, 23 ,4r41gn ce,rtitication and hearing. Therefore, 11 you haven't completed that st ge, then those issues are ripe for 24 _
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. o 67 1 CHAIRMAN PALLADINO: But this says you have to 2 litigate --
3 MR. OLMSTEAD: Excuse me, that's the second time. I 4 want to correct the misunderstanding. If you certify the 5 design by rulomaking, it's not. litigable in a hearing. If you 6 don't certify it, then it*s still litigable.
7 MR. MIRAGLIA: That's all in --
B CHAIRMAN PALLADINO: All aspects of it are still 9 litigable?
, 10 MR. OLMSTEAD: Right. Anything that's in 11 rulemaking. You can combine an early site review and a 12 standardized, certified design and essentially foreclose 13 everything except the site-specific offsite issue.
14 COMMISSIONER ZECH: Which is what we intend to do.
15 CHAIRMAN PALLADINO: Let me finish my line of 16 questioning, because under certified design it doesn't say 17 anything really about rulemaking, unless I missed something.
18 Oh, yes, I guess it does. It says certified final 19 design is not subject to litigation in individual licensing 20 proceedings. And these are applications. That is on the 21 basis that it goes to rulemaking.
22 Then when it comes to final design approval, it says 23 litigation -- an approved final design is subject to litigation 24 and individual licensing proceedings. That's because we 25 haven't gone rulemaking?
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1 COMMISSIONER ASSELSTINE: That's right. Design 2 approval is'Just the Staff sign-off, the Staff is satisfied, t
3 without the Commission process for approving, certifying it.
4 CHAIRMAN PALLADINO: Okay.1 Sorry to interrupt. Why 5 don't we continue, give you a chance to continue.
6 MR. MIRAGL'lA: The last point would be on what's the 7 basis for making changes on a design approval, and the Staff 8 has indicated.it can be based on the backlit rule. The 9 industry eqnsidered that application should be based on the 10' backfit on the lead' plant, the difference 1 being, as we g , i 7 11 perceiv,e, using the backfit rule on the plant that we are s'
12 considering.
3
^ 13 CHAIRMAfd PALLADINO: I think we have a real problem 14 it we start to do extensive backlitting on the plants that are 15 being replicated'or duplicated.
16 MR. MIRAGLIA: What the concepts say is we would t
i 17 follow Commission's policy with regard to this.
18 MR. STELLO: .The issue, I think, is a simple one.
19 If you are going to backlit, you are going to have to follow 20 the rule. If you base it on the lead plant, which could 21 conceivably be already constructed and operating, then the i
22 considerations in deciding whether or not to backiit would be
' ~
23 completely different than 11 it were a new. plant being 24 designed. And the backtit rule recognizes those differences 25- and tel1s you whai to d o '. ' And a11 we said is)that we are A
. , , - . .i - - . ~ . - - ,e-- . .
. o 69 1 following the rule. Their proposal would be a departure from
,m 2 the rule.
3 COMMISSIONER ASSELSTINE: Yes. That's right.
4 Because considerations could be very, very different. You 5 could hane a plant that is just going into operation now that 6 was designed really in the '60s. Some of them were literally 7 designed in the 1960s. If you are starting off with a new --
8 without a plant being built, considerations are quite 9 different.
10 CHAIRMAN PALLADINO: I'm having trouble, though. Il 11 we start to change the plant, then is it a duplicate or a 12 replicate?
13 MR. STELLO: Clearly the intent is not to change it 14 at all.
15 MR. MIRAGLIA: That's right.
16 MR. STELLO: But 11 you do change, you are required 17 to follow the Commission's backiit rule. In following that 18 rule, there are two ways t ; do it. We want to follow it 19 literally as it's spelled out in the backfit rule, and they 20 are suggesting something ditterent.
21 MR. MIRAGLIA: That completes the presentation from
, 22 the Staff. The proposed policy statement was here a response 23 to the Commission's request for us to provide something for 24 their. consideration to share for public comment.
25 CHAIRMAN PALLADINO: I very much appreciate receiving
l 70 l
1 the policy statement. I think we had a good discussion. It
, 2 helped clarity a number of points.
3 Let me ask the Commissioners how they feel on 4 proceeding. One, we could say, well, let's each of us try to 5 vote on this paper and maybe the vote sheet would have a 6 number of suggested changes. I have some I would like to 7 propose. And then see where we stand.
8 Or do you feel there is some other approach such as 9 going after some particular information?
10 Now I know you would like to get on certain issues 11 information from the FAA, but I'm not sure that they are 12 necessary in this policy statement.
' 13 COMMISSIONER BERNTHAL: I think that the suggestion 14 that Vic or Jim, somebody, made here would show that we get a 15 better idea from the utilities themselves of what they might 16 in their wild imagination contemplate for the next five years 17 or so is worth pursuing. Maybe that could be folded into the 18 AIF request. I don't know. Maybe NUMARC is the better 19 vehicle for that. But I have to say -- again I will say that 20 these distractions -- I can't remember what we're calling them 21 .any more --
replication and duplication are just distractions.
22 If you stop and think about what we are talking about here, I 23 don't think anyone, not even Fred Bernthal in some speeches l
24 he's made, suggesting you might see construction by 1990 or l l
25 shortly thereafter, has suggested that within five years from i
1
I
.- o 1 1
71 1 now we will see new plant applications. And then the question
.m 2 becomes in 1989 or 1990, actually Staff is saying five years l 3 from *83, I guess -- 1988, if you will -- would we approve for 4 replication a plant, to pick an example, that has an identical 5 control room to the one that we approved in 1983, with the 6 advances in control technology that we all know are going on, 7 and that in my judgment are essential? I think the answer is 8 probably no. I don't think you can do that in 1990. I don't 9 think you would approve a control room of early 1970s design.
10 CHAIRMAN PALLADINO: We'd better watch; otherwise, 11 we are going to be the ones that don *t want standardization.
12 COMMISSIONER BERNTHAL: I think we want to drive 13 toward the thing that we are heading for, which is design 14 certification. That is standardized plants. Now if you can 15 demonstrate that there is any remote chance that a utility 16 might have in mind coming in, let's say, by 1990, then we have 17 got something we have to consider. Otherwise, I'm not sure 18 that it's not irrelevant.
13 CHAIRMAN PALLADINO: Let's be careful. Otherwise, 20 we will shoot standardization in the foot before we ever get 21 it off the mark. Because standardization is going to require 22 some fixing of the technology in point of time. That does not 23 mean that after a period of time you shouldn't say we want a 24 different fix, but it does mean for a period of time you 11x 25 the technology --
and when I say standardization, I picture
72 1 those reactors.at Fukashima where you walk down and, except
! 2 for the-designation-on.the building, you couldn't tell whother 3 you. wore in one, two, three or four.
4 COMMISSIONER BERNTHAL That's right. But they 5 didn*t have a - -well, whatever it is, a 15 or 20 year gap 6 between.--
7 CHAIRMAN PALLADINO: I understand how they got 8 there, and that they face a different set of circumstances.
4 9 But we have got to be ready to admit that we are going to fix 10 technology application in point of time, and then have discrete l
11 points'in time in which we would encourage new ones. Just like i
12 we got the DC-3. Some of them are still running, but that
, (N 13 doesn't mean --
14 COMMISSIONER BERNTHAL: We don't. build them any 15 more.
I 16 COMMISSIONER ASSELSTINE: But you don't build a new.
f f 17 one.
18 CHAIRMAN PALLADINO: That's right. But'we didn*t 19 start changing it at every one. We just stopped the DC-3 and 20 went on to others. What I'm saying.is you fix the ~ technology 21 in point of time.
I 22- COMMISSIONER BERNTHAL But we are driving to design 23 certification. That's what standardization i s ', it seems to 24 me. Anything else in the interim depends on whether there's 25 going to be any practical.need for it, it seems to me, and l
l
73 1 that is something we can ask the utilities. It is not clear l
-, ~s 2 to me that we will be --
3 CHAIRMAN PALLADINO: Let me make a suggestion. I do 4 think it is wise to get the opinions of the utilities, but I
$ would say in the meanwhile we ought to try to fix up this 6 policy statement to be more in keeping with the points we 7 would like to see, such as clarification in terminology, and 8 then get it out for comment. Because the comments will also 9 bring us information that we can use.
10 COMMISSIONER ZECH: Let me make a comment, 11 I may, 11 coup 1'e of commente.
12 First of all, this Commission and the Staff has
<' 13 obviously been talking about standardization for a long' time.
14 Not much has happened, in my view. I think now is to the time 15 to be serious about it.
16 I do think, though, the Staff has done a very good 17 job in trying to wrestle with this subject and a big part of 18 it, a big difficulty, is the timing issue. Here we are in 19 this country living with all these customized plants. Most 20 everyone, I believe, agrees that it is sound logic, it's in 21 line with public health and safety, it's a sensible thing to 22 do to standardize.
23 Now how do we get from where we are to where we are 24 going? It seems to me timing is really part of what we are 25 talking about and it's a big, big thing to be considering, and i
y -e 74 1 so we can't just, I don't think -- even though it might be ,
s 2 highly desirable to say put out a very rigid standardization 3 policy, from now on it's going to be one design, two, three, 4 six or whatever, and that's it. It seems to me -- and this is 5 why I have used the term generations before. I think about it 6 this way, anyway. I think we ought to have two generations of 7 standardization.
8 The first generation, the next one that comes along, 9 would include some features of duplication and replication as 10 it is understood in the industry. I think it just makes 11 sense. We can't foreclose that, in my judgment.
12 Also in the first generation we might include a
~
, 13 third category. That would be perhaps under duplication, 14 perhaps under replication, but at least what I would call an 15 evolutionary change. We might find a plant out there that we 16 think is acting -- is performing reliably, safely, it's got a 17 fine record and so forth, and we might consider that in what I 18 term the third category of first generation It's an ^~
19 evolutionary plant, something out there right now that*s 20 operating very well, with some modifications to it. That, to 21 me, is a first generation. I look at that as a very 22 conservative approach, but a realistic approach.
23 The second generation I look at in two categories:
24 Ono, the advanced reactor. We don't know what that 25 is going to be, but hopefully that is being worked on.
y *
?S 1 And also, the second category then of the second 2 generation would be perhaps even a more evolutionary change 3 towards what we have learned from the first generation. To 4 me, if you put it in those categories, it kind of makes 5 standardization feasible, rather than just be concerned with 6 all the difficulties it looks like in getting from here to
? there. So I think that's a good way to think about it B So I have this recommendation. I think that the 9 Staff has put together a good paper. I would suggest that we 10 give the paper to OPE and that our Commission level offices --
11 the Commissioner offices
- assistants work with OPE and with 12 the Stati input also to make the modifications that are 13 necessary to the paper.
14 I also agree that we should get an input from 15 industry. I think NUMARC would indeed be an appropriate 16 group, although I think AIF, EPRI, EEI, others may be 1? interested in participating, too.
18 I think somebody has got to kind of try to get a 19 consensus, but you probably won *t, and therefore then we would 20 give options who wants what and so forth. That kind of a 21 proposal I would recommend, and also we should try to come up 22 with a policy to give strong guidance as to what we really 23 want.
24 But again, my thinking is this is first generation, 25 second generation, so it is feasible. As we mentioned earlier,
g 4-76 1 we don't want to make it so impossible it's not going to 2 happen.
3 On the other hand, we are looking out for the public 4 health and safety, we are looking out for the citizens of our 5 country who should benefit from standardization. That is 6 important to me.
7 Then I would envision after that has been reworked 8 that we eventually put out -- and it should not be reworked to 9 he so prescriptive that it has all the fine points that we 10 even talked here today and perhaps discussed, but it should be 11 a general firm guidance, maybe not as specific as we would 12 like, and certainly not as proscriptive, but something that we 13 consider a sensible policy, 'and then we should supplement it 14 eventually with a NUREG that would perhaps discuss the issues 15 and topics in executicn, some of which we have talked about 16 here today, too. It seems to me that is the approach we ought i
17 to take.
18 So I think the Statt has done a good job, but it is i
19 a very important issue, and we should- not let it drag on 20 forever. It need not. But I do think that that kind of a 21 review with all of our. Commissioner ottices participating 22 would be a responsible thing to do.
23 I think that the Commissioners have a responsibility 4
24 now. The Stati has done a iine job, and now 1t is up to us, I 25 think, to take a more active role. I suggest that*s what we l i
I l
i
t
- 77 1 do.
2 CHAIRMAN PALLADINO: I was proposing that we get 3 our input in. We can get it in through our assistants. That 4 is a perfectly acceptable way, as far as I am concerned. I 5 was trying to avoid the time lag being too great, because 11 6 we go for outside opinions, I'm not sure how quickly we are
? going to be able to get them. But 11 we can go out for the 8 outside opinions while our staffs are working with OPE and the 9 Statt, then we might be able to save a little bit of time.
10 I'd like to see us get the standardisation policy out the 11 first half of 1986.
12 COMMISSIONER ZECH: I'm all for getting it out soon, 13 but it*s so importa'nt. I think we ought to do it right, and I 14 think'many of the things I have said can be done in parallel.
15 CHAIRMAN PALLADINO: Sure.
16 COMMISSIONER ZECH: I don't think we have to take 17 forever to get it done at all, but it seems to me that input 18 from industry and those groups we have mentioned is important 19 because, as was mentioned, they are the customer and the 20 customer really is the citizens of our country, eventually.
21 That is important. We should keep that in mind.
22 CHAIRMAN PALLADINO: This would be going out for 23 comment, anyhow.
j 24 COMMISSIONER ZECH: That*s why it is so im:ortant we 25 have it coordinated the best we can.
s =
78 1 CHAIRMAN PALLADINO: As I understand it, you propose N
2 that we get our assistants working together with OPE 3 participating?
4 COMMISSIONER ZECH: The Stati should be involved. I 5 suggest they get somebody full time from the Staff to 6 participate in this group, 11 they can, and we coordinate 7 again with industry folks.
8 CHAIRMAN PALLADINO: Another way we have generally 9 done is provided our input to the Staff and asked them to 10 revise it. That is the one I would preter, but --
11 COMMISSIONER ZECH: The Staff has done that.
12 CHAIRMAN PALLADINO: No, generally we react. One 13 way to r e a'e t is to get OPE and the staffs, our individual 14 statis, working together, and then we can give it back to OPE 15 -- I mean give it to EDO and ask them to revise it. However, 16 I am open to innovative approaches.
17 COMMISSIONER ZECH: That is just my view. Others 18 may not feel the same way.
19 COMMISSIONER BERNTHAL: I don't know. I'm not sure i
20 where we are. I think that somehow we are not keeping our eye 21 on the ball We are confusing things with possibilities that 22 might arise in the next five years.
23 It seems to me the objective is for this country to 24 have our equivalent of Sizewell II ready for the 1990s. It 25 may well be that a utility, one or more utilities comes in in
o
- 79 1 the intervening years -- by 1990, perhaps -- and says, "We
._, 2 wr,uld like to finish up the plant we started," or, "We would 3 like to replicate somebody else's plant." That, I think, is a
, 4 minor element of the standardization policy.
5 The major element is a design certification for 6 every major vendor, assuming they are willing to step forward 7 and proceed with it. I think there are some innovative ideas 8 here for driving that process of standardization, promoting 9 the process of standardization with some of the financing 10 ideas that have been suggested by the Staff, and I think what 11 we are really a f.t e r here is a design certification of a 12 Sizewell type at a Sizewell type level
[ 13 If I ask myself, are we going t'o be inclined to 14 approve 1990 and beyond a plant that is a replicate of an 15 existing plant today, I am not sure what the answer would be.
16 I doubt we would approve that control technology.
17 CHAIRMAN PALLADINO: But, Fred, I think you are 18 talking to the substance of the issue, and we have to address 19 the substance of the issue, but I was trying to get a feel for 20 how to proceed.
21 COMMISSIONER BERNTHAL: I understand.
22 CHAIRMAN PALLADINO: We have a variety of workable 23 schemes, it we just get agreement that we want to follow a 24 particular scheme, because we want to make sure this Commission l
l 25 input is provided and the suggestion that the assistants get
e
- 80 1 together with OPE to develop a consensus position. I think that m
\ ! 2 is a good approach.
3 Then what do we want to do about resolving --
4 COMMISSIONER BERNTHAL: It doesn't matter to me how 5 we go about this.
6 CHAIRMAN PALLADINO: Except to pick one.
7 COMMISSIONER BERNTHAL: I think the pieces are 8 basically there, and what the Staff has given us, and why 9 isn't a different --
10 COMMISSIONER ZECH: I don't iind any iault with what
.i 11 you are saying at all. I think we are in sync on it. I am 12 just trying to get the thing moved on. I think it is the
^'
13 Commissioners' responsibility now to try to play a little more 14 active part. I think the Staff has done a fine job. They 15 have gone about as far as they can go.
16 I agree with what you are saying. I think we are 17 pretty much in agreement on what we want to do, and I think 4
18 Ccmmissioner Asselstine and I have always felt pretty much the 19 same way about this. I am just trying to figure out a way to 20 move it along and work it out as quickly as we can, 21 COMMISSIONER ASSELSTINE: For myself, I don't care 22 who does it. OPE can do it, or the Staff, and I don't have j 23 any problem with providing our input. I guess I view things 24 as Fred has just described them. I think that is more of a 25 restructuring of what is here than simply line-tuning or
81 1 editing, and I think somebody is going to have to put some m
2 effort in if that's the way the consensus of the Commission is 3 oriented.
4 I think Fred hit it right on the nose. Some of this 5 other stuff, in my view, clutters up what we are really after 6 here. If somebody wants to ocme in and say -- and build a 7 duplicate of something that now exists, that's fine, we should 8 not preclude that. But to highlight that as an element and 9 feature of our standardization policy, I think is a mistake.
10 I agree with Fred on that. It seems to me what we ought to 11 say is standardization what we're looking for, or the certified 12 designs that look into the future? That's what this program is 13 oriented towards, and let's build on what's in this policy 14 statement on that aspect of it and use it and take out some of 15 this other stuff and look at those things on a case-by-case 16 basis. If anybody really is interested in pursuing them.
17 I would like to see, you know, some effort made to 18 reformulate the policy statement along those lines; whether 19 it*s OPE or the Staff doesn't matter to me.
20 CHAIRMAN PALLADINO: What we are trying to do is 21 provide a vehicle whereby individual Commissioner viewpoints, 22 such as Fred's and yours --
23 COMMISSIONER ZECH: I think we can do just that.
24 Perhaps we do differ a little bit in the fact that I believe 25 we should at least recognize that duplication and replication
r -
i e
- 82 1 for the immediate future is a very real possibility. I don't 2 think eliminating them would be the appropriate thing to do, 3 but I certainly agree that we should emphasize our goal of 4 getting to a certification, a standardization program that is 5 very real.
6 On that, I certainly agree, but I think that's why I
? look at it in generations. I think we have to do it in steps 8 or else nothing is going to happen. It we put out a very.
9 rigid policy eliminating all chance of duplication, eliminating 10 all chance of replication, I simply don't think anything is 11 going to happen. We are not going to get anywhere in building 12 plants in our country. I think that would probably be an 13 irresponsible regulatory action on our part.
14 COMMISSIONER BERNTHAL: I don't think anyone is 15 suggesting that. It's a question of emphasis, and I guess the 16 only reason for dwelling a bit further on the policy 17 inclinations here at.the table is that it might better 18 determine how we want to proceed with the Gtaff and whatnot.
19 COMMISSIONER ASSELSTINE: Yes.
20 COMMISSIONER BERNTHAL: It's a question of emphasis, 21 I agree.
22 CHAIRMAN PALLADINO: Let me make the suggestion, 23 picking up your point, that we each give our respective views 24 to our assistants, and then the assistants, working with the s
[ 25 OPE, meet to reach a consensus on what ought to be done with i
l I
< a 83 1 regard to this.
2 COMMISSIONER ASSELSTINE: Sure.
3 COMMISSIONER ZECH: Very good.
4 CHAIRMAN FALLADINO: Then in parallel I would also i 5 ask the Staff to discuss with NUMARC, or perhaps some other 6 group, 11 it seems more appropriate, to get background 7 information on how the utilities view various options, and I 8 also would ask the Staff to find out a little more about how 9 FAA and aircraft designers manage the antitrust questions.
i 10 COMMISSIONER ZECH: Okay.
11 CHAIRMAN FALLADINO: Thank you very much, gentlemen.
12 That was a very interesting discussion.
13 Okay, we will stand adjourned.
- 14 [Whereupon, at 12
- 05 p.m., the meeting was 15 adjourned.')
16 17 ,
18 19 20 21 22 23 24 25
1 CERTIFICATE OF OFFICIAL REPORTER 2
3 4
5 This is to certify that the attached proceedings 6 before the United States Nuclear Regulatory Commission in the 7 matter of: COMMISSION MEETING 8
9 Name of Proceeding: Briefing on Policy Statement on Nuclear Power Plant Standardization (Public Meeting:
10 11 Docket No.*
12 P1 ace: Washington, D. C.
13 Date: Wednesday, December 11, 1985 14 15 aare held as herein appears and that.this is the original 16 transcript thereof for the file of the United States Nuclear 17 Regulatory Commission.
13 s . f S* *
- g h k } @ w 1.- \/ ( (lr--
(Typed Name of Reporter) Mimie Melty)z r' 20 21 22 23 Ann Riley & Associates, Ltd.
-w 24 25
, e' 12/11/85 PROPOSED REVISION TO STANDARDIZATION POLICY STATEMENT -- BRIEFING OUTLINE BACKGROUND NEED FOR REVISING 1978 STANDARDIZATION POLICY STATEMENT RETAINED PRESENT STANDARDIZATION CONCEPTS SIGNIFICANT PROPOSED REVISIONS TO 1978 STANDARDIZATION POLICY STATEMENT TRANSITION REPLICATION PROVISIONS
- DIFFERENCES BETWEEN STAFF- AND AIF- PROPOSED STANDARDIZATION POLICIES i
FMIRAGLIA/NRR x27980 l l
l
- _ . -- . _ . _ _ - . _ - . . _ _ . _ _ . - . ---- _ J
1 BACKGROUND APRIL 1972 INITIAL POLICY STATEMENT ISSUED MARCH 1973 REFERENCE SYSTEM, DUPLICATE PLANT AND MANUFACTURING LICENSE CONCEPTS ANNOUNCED AUGUST 1974 REPLICATE PLANT CONCEPT ANNOUNCED JULY 1977 STATEMENT REAFFIRMING SUPPORT OF STANDARDI-ZATION, AND REQUESTING COMMENTS AND SUGGESTIONS ON CHANGES ISSUED AUGUST 1978 MOST RECENT POLICY STATEMENT ISSUED FMIRAGLIA/NRR x27980 j
l t I
. t #
r, NEED FOR REVISING 1978 STANDARDIZATION POLICY STATEMENT STAFF'S EXPERIENCE IN IMPLEMENTING STANDARDIZATION PROGRAM PROVISIONS OF SEVERE Acc! DENT POLICY STATEMENT PROVISIONS OF DRAFT NUCLEAR POWER PLANT LICENSING AND STANDARDIZATION AcT STAFF'S CURRENT VIEWS ON STANDARDIZATION i FMIRAGLIA/NRR x27980
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RETAINED PRESENT STANDARDIZATION CONCEPTS .
1 REFERENCE SYSTEM 4
4
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o s SIGNIFICANT PROPOSED REVISIONS TO 1978 STANDARDIZATION POLICY STATEMENT SEVEPE ACCIDENT POLICY STATEMENT LICENSING REQUIRENENTS DESIGN CERTIFICATION OPTION STAFF / COMMISSION CHANGES TO APPROVED DESIGNS MORE RESTRICTIVE; INDUSTRY CHANGES LESS RESTRICTIVE DUPLICATE-PEPLICATE PLANT REFERENCEABILITY PERIOD OVERLAP ELIMINATED REFERENCE DESIGN FEES ALLOCATED AMONG USERS FDAS AND DCS RENEWABLE; PDAS RENEWABLE FOR GOOD CAUSE FMIRAGLIA/NRR x27980
4
~
TRANSITION REPLICATION PROVISIONS REPLICATION PERIOD EXTENDED TO 5 YEARS FROM POLICY STATEMENT ADDED FLEXIBILITY IN APPLYING POLICY STATEMENT REQUIREMENTS NUREG-0800 PLANTS - ANY SITE NON-NUREG-0800 PLANTS - SAME SITE AND OPERATOR AS REPLICATED PLANT .
FMIRAGLI A/NRR X27980
! - DIFFERENCES BETWEEN STAFF- AND AIF-PROPOSED STANDARDIZATION POLICIES -
i i ISSUE STAFF AIF d
TERMS OF APPROVAL DC - 10 YEARS; ALL CONCEPTS -
OTHERS 5 YEARS 10 YEARS PDA RENEWABILITY FOR GOOD CAUSE YES LEVEL OF DESIGN DETAIL EQUIVALENT TO LESS THAN FOR FDAS AND DCS FSAR FSAR COST-BENEFIT ANALYSIS BASED ON BACKFIT BASED ON LEAD i
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