ML20138Q097
| ML20138Q097 | |
| Person / Time | |
|---|---|
| Issue date: | 12/20/1985 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Owen W DUKE POWER CO. |
| References | |
| NUDOCS 8512270050 | |
| Download: ML20138Q097 (2) | |
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. 4 DEC 2 01985 Mr. Warren H. Owen Executive Vice President Duke Power Co.
P. O. Box 33189 Charlotte, NC 28242
Dear Mr. Owen:
At the December 11,1985 Commission meeting to discuss the proposed revision to the 1978 Policy Statement on Standardization (SECY 85-382) (Enclosure 1),
the Comission was informed that in revising the Policy Statement the staff had worked closely with the Atomic Industrial Forum (AIF) Study Group on the Practical Application of Standardized Nuclear Power Plants in the United States, chaired by Mr. John Ward. However, the Comission directed the staff to also obtain the additional views cf the Nuclear Utility Management and Human Resources Comittee (NUMARC), the Electric Power Research Institute (ERPI) and the Edison Electric Institute (EEI). The Commission was specifically interested in determining whether the four concepts, as currently described in the proposed policy statement, are adequate and/or necessary to meet the pro-jected short-term and long-term needs of the nuclear industry. In other words, should a utility desire to build another nuclear unit in the future, is this the correct set of options that should be available for the decisionmaking process? The four concepts addressed in the proposed Policy Statement are:
Reference System Concept, including Design Certification; Duplicate Plant Concept; Replicate Plant Concept; and Manufacturing License Concept. In order to fully understand the individual concerns of the Commissioners, Enclosure 2 is a copy of the Commission meeting transcript.
I would appreciate receiving any comments you may have regarding the questions raised by the Commissioners by January 21, 1986.
Sincerely, Original Signed by V. Stello 851227005o 851220 Victor Stello, Jr.
PDR TOPRP EUTDPC C PDR Deputy Executive Director Regional Operations and Generic Requirements //
Enclosures:
- 1. 1978 Policy Statement /j f
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g db on Standardization (SECY-85-382) ipP]M
- 2. Transcript of Commission Meeting on Standardization (12/11/85) hf I,h cc: See next page d 0FC :ROGR/S :ROGR/D :DEDROGR : : : :
NAME :RCapra .JHSniezef .VStello : : : :
DATE :12/13/85 :12/ /85 :12/ /85 : : : :
0FFICIAL RECORD COPY
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cc w/o encl:
Mr. John Ward i Chairman Palladino-Commissioner Roberts Commissioner Asselstine l Commissioner Bernthal Commissioner Zech Distribution (w/o encl):
4 WJDircks VStello HDenton JHSniezek DEisenhut FMiraglia HBerkow DScaletti
-0PE SECY RCapra DEDR0GR cf PDR (w/ encl.)
Central File (w/ encl.)
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Identical Letter Sent to:
Mr. Loring Mills Vice President Nuclear Activities Edison Electric Institute-
'1111 19th St., NW Washington, DC 20036 Mr. John. Taylor Vice President and Director l Nuclear Power Division
- Electric Power Research Institute
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1 3412 Hillview Ave.
- P. O. Box 10412.
Palo Alto, CA 94303 (w/cc: Dr. Gene Mannella, local DC office) 4
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December 4,1985 POLICY ISSUE. SECY-85-382 (Comm.ission Meet.ing)
For: The Comissioners F' rom: William J. Dircks Executive Director for Operations
Subject:
. STANDARDIZATION POLICY STATEMEC'
Purpose:
To respond to those portions of the staff requirements memoranda dated February 22 and April 5, 1985 which requested the staff to prepare for the Comission's consideration a draft revision to its 1978 standardization policy statement. The draft policy statement is provided as Enclosure 1. The balance of the staff's responses was provided in a memorandum to the Comission dated March 18, 1985.
Background:
The initial policy statement of the Atomic Energy Comission (AEC) on nuclear power plant standardization was issued in April 1972. In March 1973, the AEC announced its readiness to implement its standardization policy utilizing three distinct concepts--the reference system concept, the duplicate plant concept and the manufacturing license concept. In August 1974, the AEC announced a fourth standardization concept--the replicate plant concept. On January 19, 1975, the AEC was
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abolished and its regulatory responsibilities were assigned to the newly-formed Nuclear Regulatory Comission (the Comission).
In July 1977, the Comission issued a statement that reaffirmed its support of standardization and requested coments and suggestions on proposed program changes and other steps it might undertake to further encourage standardization. The Comission's most recent standardization policy statement was issued in August 1978. That policy statement described in detail the conditions that must be met for each of the standardization concepts, and extended their terms of approval.
Despite the lack of new plant orders, and the numerous cancellations and deferrals of plants already ordered in CONTACT:
D. Scaletti, NRR 49-29787 f! 2, p '!?$$
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r The Comissioners recent years, considerable use has been made of standardization since its inception. A sumary of the implementation of the standardization program to date is provided as Enclosure 2.
The Comission recently issued its severe accident policy statement which sets forth licensing requirements for new plant designs, both standard and custom. In addition, the Comission has proposed to the Congress its draft " Nuclear Power Plant Licensing and Standardization Act of 1985" which
- would provide for the issuance of combined construction permits and operating licenses in a one-step licensing process, early site approvals and standard design approvals.
Finally, considerable additional experience has been acquired
- in implementing the standardization program. Therefore, we believe that it is appropriate at this time to revise the 1978 standardization policy statement to reflect these initiatives. .
Discussion: The draft revision to the 1978 policy statement reflects the applicable provisions of the severe accident policy statement and the draft " Nuclear Power Plant Licensing and Standardization Act of 1985." It also reflects the experience we have acquired in implementing the standardization program since 1978 and our current views on standardization.
The draft policy statement identifies the reference system design certification as the true goal of standardization, but recognizes that the duplicate plant, replicate plant and manufacturing license concepts are necessary options that should be maintained. Industry representatives have indicated that the types of applications most likely in the near term will include reactivation of deferred plants and replication of previously-licensed plants. Policies and procedures regarding t
I deferred plants are being developed separately from this policy statement. The staff has included in the draft policy statement two transition options relating to replication of previously-licensed plants. These options address replicationof recently-
- licensed plants, which have been reviewed against NUREG-0800, and replication of earlier-licensed plants, which have not been reviewed against NUREG-0800. The staff believes that these transition options should conform with the provisions of the draft policy statement. However, during the transition period, the staff recommends that the reference period for replication l of such plants be extended for five years from the effective
J The Comissioners i b
4 date of the revised policy statement. In addition, the staff recomends that consideration be given to relaxation of the l
other provisions of this policy statement during this !
lI five-year period if suitably justified.
The most sigr.ificant proposed revisions to the 1978 standard-ization policy statement are outlined below. A more detailed ;
discussion of these revisions is provided in Enclosure 3. '
s (1) The four licensing requirements for new plant designs as set forth in the Commission's severe accident policy 7 i statement have been added.
t (2) Provisions for design certification through rulemaking have been added.
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] (3) The ability of the staff and Comission to make changes i to approved or certified designs has been made more
- restrictive. An explanation of the a the backfitting rule (10 CFR 50.109) to each pplicability of the of
- options has been added. The ability of holders of design approvals or certifications to make such changes has been made less restrictive.
! (4) The overlap in the reference periods between the duplicate '
and replicate design concepts has been eliminated.
(5) Fees required of reference design applicants will be allocated among the applicants for permits and licenses
! which propose to use the reference design. Enact:nent .'
of the draft " Nuclear Power Plant Licensing and
' Standardization Act of 1985" would be necessary prior
- to adopting this approach.
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(6) Final design approvals and design certifications can be ,
renewed once for a duration up to the original approval '
period. Preliminary design approvals can only be renewed on a finding of good cause.
i To assist the staff in revising the standardization l policy statement, the Atomic Industrial Forum (AIF) formed a study group. As a result of this effort they developed
, an outline of a proposed policy statement. That outline
! is provided as Enclosure 4. The AIF's proposed standard-l ization policy is consistent with that proposed by the j staff with the exception of four differences addressed below.
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The Comissioners (1) The AIF proposes that the duration of the approvals for all standardization concepts be ten years. The staff believes that the ten-year approval period should be reserved for certified designs; all others should be five years.
(2) The AIF proposes that preliminary design approvals be renewable. The staff believes preliminary design approvals should be renewable by the staff for a period of up to five years only on a finding of good cause.
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(3) The staff believes that final design approvals and design certifications should be based on a level of design detail equivalent to that required for a Final Safety Analysis
.. Report. The AIF appears to suggest that a lesser degree of design detail should be required; however it recognizes the need to further discuss this issue with the staff.
(4) The AIF proposes that the cost-benefit analysis for staff- or Comission-proposed changes to approved designs be performed on the lead or first unit referencing the given standard design. The procedures described in the backfitting rule will establish the threshold for staff-or Comission-proposed changes to an approved design.
The Executive Legal Director has prepared for the Comission's consideration a paper describing several options for design certification rulemaking proceedings. That paper is provided as Enclosure 5.
Finally, the Office of Administration has prepared for the Comission's consideration a discussion of license fees related to the reference system concept. That paper is provided as Enclosure 6.
tamJ.Iircks Executive') Director for Operations
Enclosures:
As stated DISTRIBUTION:
Commissioners REGIONAL OFFICES OGC EDO OPE ELD OI ACRS OCA ASLBP OIA ASLAP OPA SECY
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', ENCLOSURE 1 '
! POLICY STATEMENT ON NUCLEAR POWER PLANT STANDARDIZATION The Comission continues to strongly support standardization and, while i maintaining the option for licensing new custom plants, encourages the l use of standard plant designs in all future license applications.. The Comission believes that the use of standard plant designs can benefit j i public health and safety by concentrating the resources of designers, t j engineers and vendors on particular approaches; by stimulating standardized l
- programs of construction practice and_ quality assurance; by improving the i training of personnel; and by fostering more effective maintenance and i improved operation. The use of such designs can also permit more effective
- and efficient licensing and inspection processes.
The Commission believes that the true goal of standardization shou'ld be
! the reference system design certification as outlined in this policy j statement. The Comission anticipates that over the long term the majority j of new plant applications will incorporate approved or certified reference ,
l system designs. However, the Comission recognizes that the duplicate :
1 plant, replicate plant and manufacturing license options have also '
j contributed to the progress that has been made in standardization to date i
and, therefore, continues to endorse the use of these options. Each of the
- standardization concepts and their terms and conditions are discussed l _below.
i In addition to the four standardization concepts identified above, the Commission has provided flexibility in the application of the replication ' ,
concept to allow for a transition period. This provision of the policy ,
l statement is also discussed below.
- 1. Reference System Concept l
} The reference system concept involves an application for approval or ,
i certification of an entire auclear power plant design or major portion !
l thereof outside the context oi an application for a construction permit. - !
1 . operating license, combined tenstruction pemit and operating license, or j manufacturing license. Approvals are +
of preliminary design approvals (PDA) granted by the staff in the formsand final :
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- preliminary and final levels of design detail, respectively. Certification j is granted by the Commission in the form of design certifications for final j lev 21s of design detail only.
To further encourage the use of the reference system design option, the i Comission will not require application filing or issuance fees for reference design approvals, certifications or amendments or renewals thereof.
The fees that would otherwise have been required of reference design applicants will be allocated among the applicants for construction permits, operating licenses, and combined construction permits and operating licenses !
which propose to use the reference design. If no application for a permit !
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! or license for a facility is filed within the initial term or the renewal
- period of the design approval and/or certification, any outstanding fees will
- become immediately due and payable by the holder of the reference design l
} ' approval or certification.
In accordance with 10 CFR 50.109, once the initial design approval is issued (i.e., PDA or FDA) the Commission will not require modification to an approved or certified design unless it determines that such modifications ,
! provide a substantial increase in the overall protection of the public '
i health and safety or the common defense and security. However, holders of ,
, design approvals or certifications may modify the approved or certified l design by applying for an amendment to the design approval or certification. !
- Any such amendments will only be required to apply to applications for
' construction pennits, and combined construction permits and operating l licenses that are submitted after the amendment is issued unless the modifi- i cations are required to provide a substantial increase in the overall ,
protection of-the public health and safety or the comon defense and security.
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! a. Preliminary Design Approvals l A preliminary design approval is issued by the staff following the completion
- of its and the ACRS's reviews of the preliminary design. It deems an entire ,
i nuclear power plant design or major portion thereof acceptable for incorpora-
.i tion by reference in applications for construction permits and manufacturing i licenses. It also provides that the approved preliminary design shall be l utilized and relied upon by the staff and the ACRS in their reviews of those i applications. However, an approved preliminary design is subject to litigation in individual licensing proceedings on those applications. A l preliminary design approval is not a prerequisite for a final design j approval or a design certification.
l An application for a preliminary design approval must include to the extent t
practicable a level of design detail equivalent to that required for a preliminary safety analysis report. In addition, it must address the .
, four licensing requirements for new plant designs as set forth in the
[ Comission's severe accident policy statement.
l Preliminary design approvals will be issued with terms of five years. Not i less than one year or more than three years prior to the expiration of the l preliminary design approval, holders of the approval may apply for the renewal
! thereof. The approval will be renewed for an additional period of time of j not more than five years provided the design is found to comply with the
! Comission's current regulations and a showing of good cause (e.g., good
! cause may be established by a pending application that would reference the l PDA during the renewal period).
l The preliminary designs may be referenced in applications for construction I permits and manufacturing licenses docketed during the period comencing i
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- with the decket?ng date of the preliminary design approval application and I terminating five years from the date of issuance of the preliminary design i approval. However, no construction permit or manufacturing license will be
! issued for applications referencing the preliminary design prior to the
- issuance of the preliminary design approval. Further, any changes to the i preliminary design that result from the design approval process will be i required to be reflected in those applications as well. The expiration of i the preliminary design approval will not affect the use of the approved preliminary design in applications for construction permits and manufacturing i ljcenses docketed prior to its expiration.
- b. Final Lesign Approvals A final design approval is issued by the staff following the completion of
, its and the ACRS's reviews of the final design. It deems an entire nuclear power plant design or major portion thereof acceptable for incorporation by reference in applications for construction permits, operating licenses, combined construction permits and operating licenses in a one-step licensing, and manufacturing licenses. It also provides that the approved final design j
shall be utilized and relied upon by the staff and the ACRS in their reviews
. of those applications. However, an approved final design is subject to i litigation in individual licensing proceedings on those applications. A final design approval is a prerequisite for a design certification.
i An application for a final design approval must include to the extent ;
i practicable a level of design detail equivalent to that required for a i final safety analysis report. In addition, it must address the four licensing requirements for new plent designs as set forth in the
- Connission's severe accident policy statement. -
Final design approvals will be issued with terms of five years. Not less
- than one year or more than three years prior to the expiration of the final i design approval, holders of the approval may apply for the renewal thereof..
l The approval will be renewed for an additional period of time of not more t
- than five years provided the design is found to comply with the Commission's current regulations. ,
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- The final designs may be referenced in applications for construction permits, operating licenses, combined construction permits and operating licenses, and manufacturing licenses docketed during the period coraencing
, with the docketing date of the final design approval application 7.nd i terminating five years from the date of issuance of the final design
! approval. However, no construction permit, operating license, combined
- construction permit and operating license, or manufacturing license will be issued for applications referencing the final design prior to the issuance
- -of the final design approval. Further, any changes to the final design that j result from the design approval process will be required to be reflected in i
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i those applications as well. The expiration of the final design approval will not affect the use of the approved final design in applications for construction permits, operating licenses, combined construction permits and
- - operating licenses, and manufacturing licenses docketed prior to its expiration, and operating license applications that referenced the final
!. design approval at the construction permit stage. !
- c. Design Certifications i
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. A design certification is issued by the Cr.mnission following the issuance '
of a final design approval by the staff and the completion of a rulemaking
- proceeding. It deems an entire nuclear power plant design or major portion l thereof acceptable for incorporation by reference in applications for construction pemits, operating licenses, combined construction permits and operating licenses in a one-step licensing process, and manufacturing licenses.
It also provides that the certified final design shall be utilized and relied ,
l upon by the staff, the ACRS, the hearing boards and the Connission in their
- review of those applications. A certified final design is not subject to litigation in individual licensing proceedings on those applications.
An application for certification of the final design may accompany the application for a final design approval; however, it must be submitted
) prior to the issuance of the final design approval, i i i Design certifications will be issued with terms of ten years. Not less ;
, than one year or more than three years prior to the expiration of the design I certification, holders of the certification may apply for the renewal j thereof. The certification will be renewed for an additional period of time i of not less than five years or more than ten years from the date of renewal .
. provided the design is found to comply with the the Commission's current I
- regulations.
l The certified designs may be referenced in applications for construction i permits, operating licenses, combined construction permits'and operating l l licenses, and manufacturing licenses docketed during the period comrr.encing
! with the docketing date of the final design approval application and *
- terminating ten years from the date of issuance of the design certification. ,
However, no construction permit, operating license, combined construction
! permit'and operating license, or manufacturing license will be issued for j applications referencing the final design prior to the issuance of the final l design approval. ~Further, any changes to the final design that result from .
! the design approval or certification processes will be required to be reflected in those applications as well. The expiration of the design c j certification will not affect the use of the certified final design in r r applications for construction permits, operating licenses, combined construction permits and operating licenses, and manufacturing licenses docketed prior to its expiration, and operating license applications that
! referenced the final design certification at the construction permit stage. L
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- 2. Duplicate Plant Concept i The duplicate plant concept involves applications by one or more utilities i i for licenses to construct and/or operate a number of nuclear power plants of essentially the same design at different sites.
3 A duplicate plant design may be referenced at both the construction permit
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and operating license stages, and in applications for combined construction permits and operating licenses in a one-step licensing process. Use of the duplicate plant design at the construction pemit stage is a prerequisite for its use at the operating license stage. Although use of the duplicate
- plant design at the operating license stage is not mandatory, that is, the operating license application may be submitted as a custom plant application, i it is strongly recomended. The approved duplicate plant design shall be
. utilized and relied upon by the staff and the ACRS in their reviews of those 7 applications. However, the duplicate plant design is subject to litigation 3
in individual licensing proceedings on those applications.
j A duplicate plant design may utilize a reference system design for an entire
- nuclear power plant or a major portion thereof. Any portions of the
- duplicate plant design for which a design certification has been issued l shall be utilized and relied upon by the staff, the ACRS, the hearing boards
- and the Commission in their reviews of applications for construction permits and operating licenses referencing the duplicate plant design. In addition, 4 any portions of the duplicate plant design for which a design certification has been issued are not subject to litigation in individual licensing proceedings on those applications.
An application for a duplicate plant must demonstrate compliance with the l four licensing requirements for new plant designs as set forth in the ;
Comission's severe accident policy statement.
! A duplicate design approval will be prepared to document the staff's approval t
! of the acceptability of the duplicate plant design for referencing in
- construction permit, operating license, and combined construction permit and operating license applications. In accordance with 10 CFR 50.109, once
- the initial duplicate design approval is issued (i.e., preliminar i
design approval (PDDA) or final duplicate design approval the (FDDA))y duplicat t
? Comission will not require modification to the design unless it determines l that such modifications provide substantial increase in the overall >
i protection of the public health and safety or the common defense and security.
j The duplicate design approval will be included in the safety evaluation report for each license application referencing the duplicate plant design.
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Duplicate plant designs may be referenced in applications for construction permits, operating licenses, and combined construction permits and operating licenses during the period commencing with the docketing date of the initial
- applications referencing the duplicate plant design and terminating on the
- date of issuance of the duplicate design approval.
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The staff will determine the acceptability of the use of a duplicate plant design in the initial applications proposing to reference such a design l during pretendering discussions with the involved utilities. Subsequent to the docketing of the initial applications, each additional application proposing to reference the duplicate plant design will be subjected to a qualification review. The qualification review will consider the following information:
- The arrangements mide with the developers of the duplicate plant design for its use;
- A discussion of the compatibility of the duplicate plant design with the characteristics of the proposed site;
- A description of any changes to the original duplicate plant design and justification for the changes;
- The status of any matters identified for the duplicate plant design in the safety evaluation report, or subsequently identified by the ACRS or during public hearings on applications referencing the duplicate plant design as requiring subsequent resolution; and I - Identification of the major contractors, with justification for the acceptability of any that are different than those used by earlier applicants using the duplicate plant design.
- 3. Replicate-Plant Concept The replicate plant concept involves an application by a utility for a license to construct and/or operate one or more nuclear power plants of essentially the same design as one already licensed, (i.e. CP or OL).
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! Thedesignoftheplantalreadylicensed(termedthebaseplantdesign)may be replicated at both the construction permit and operating license stages, and in applications for combined construction permits and operating licenses in a one-step licensing process. Replication of an approved Lase plant design at the construction permit stage is a prerequisite for its replication at the operating license stage. Although replication of the base plant i
design at the operating license stage is not mandatory, that is, the '
operating license application may be submitted as a custom plant application, it is strongly reconinended.
An application for a replicate plant must demonstrate compliance with the
- four licensing requirements for new plant designs as set forth in the
- Commission's severe accident policy statement.
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l Each application proposing to replicate a previously-licensed plant will be subjected to a qualification review to determine the acceptability of the base plant for replication and to define specific matters that must be addressed in the application for the replicate plant. In applying 10 CFR 50.109, the Comission will not require modifications to those portions of the base plant design that are replicated once it has issued the initial license for tha base plant unless it detennines that such modifications provide a substantial increase in the overall protection of the public health and safety or the common defense and security. A further requirement for qualification is that the application for a replicate plant must be submitted within five years of the date of issuance of the staff safety evaluation report for the base plant. The qualification review will consider the following information:
- The arrangements made with the developers nf the base plant design for its replication;
- The compatibility of the base plant design with the characteristics of the site proposed for the replicate plant;
- A description of any changes to the base plant design with justification for the changes;
- The status of any matters identified for the base plant design in the safety evaluation report, or subsequently identified by the ACRS or during the public hearings on the base plant application as requiring subsequent resolution;
- Identification of the major contractors, with justification for the acceptability of any that are different than those used by the base plant i applicant; and
- A discussion of how the replicate plant design will conform to any changes to the Comission's regulations which have become effective since the issuance of the license for the base plant.
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- 4. Manufacturing License Concept The manufacturing license concept involves an application for a license to manufacture a number of identical nuclear power plants at a location other than those at which they are to be operated.
The application for a manufar.turing license must address the four licensing requirements for new plants a set forth in the Comission's severe accident policy statement. In accordance with 10 CFR 50.109, once the manufacturing license has been issued, the Comission will not require modifications to the design unless it determines that such modifications provide a substantial increase in overall protection of the public health and safety or the comon defense and security.
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! Appendix M to 10 CFR 50 requires that a manufacturing license 1pecify the number of unite permitted to be manufactured. The number of units to be specified in a manufacturing license will be that number whose start of manufacture, as defined in the license application, can practically begin,
- considering the limitations inherent in the proposed manufacturing facility, during the ten-year period comencing on the date of issuance of the manufacturing license, but in no event will that number be in excess of ten.
- 5. Other Considerations i Sections 1.through 4 of this policy statement set forth the terms and conditions 'for the reference system, duplicate plant, replicate plant and manufacturing license standardization concepts, respectively. The Comission i recognizes that situations may arise that are not explicitly covered by these four concepts. Three such situations are addressed below. Other such i situations, which are expected to be few in number, will be considered on a j case-by-case basis.
Discussions with industry representatives indicate that the most likely types of license applications that will be submitted in the near future will involve reactivation of deferred plants and replication of plants that have been previously licensed. While the Comission strongly encourages the use of the four standardization concepts described in Sections 1 through 4 of I
this policy statement, it recognizes the need to accomodate these latter types of applications, each of which is discussed below.
3 The Comission acknowledges that the reactivation of deferred plants is a viable licensing option. However, because these plants are based on custom as well as standard designs, and because of the many complex factors involved, the criteria and procedures for the regulatory treatment of these plants as
, a whole will be a matter of separate consideration apart from this policy statement.
i The Comission believes that the replication of previously-licensed plants should be subject to the provisions of Section 3 of this policy statement.
However, during the transition period, the reference period for replication of such plants will be extended for five years from the effective date of this policy statement. In addition, consideration will be given to relaxation of the other provisions of this policy statement during this five-year period if suitably justified.
i Plants that have been recently licensed, that is, those plants that have l been reviewed against NUREG-0300, may be replicated for a period of five years from the effective date of this policy statement provided the application otherwise meets the provisions of Section 3 of this policy i statement. Plants so replicated may be located at any suitable site.
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, Plants licensed earlier, that is, those plants that have not been reviewed
. against NUREG-0800, may be replicated for a period of five years from the effective date of this policy statement provided that the application otherwise meets the provisions of Section 3 of this policy statement and the design performance and operating history of the base plant justifies its replication. Plants so replicated may be located only on the same site and operated by the same utility as the base plant.
Although some design differences may be encountered as a result of complying with the four licensing requirements set forth in the Commission's severe i accident policy statement, the Commission believes that replication of existing designs may offer improvements in public health and safety, and operating costs as a result of operator familiarity and improved maintenance
! due to the similarity of design.
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!' ENCLOSURE 2 IMPLEMENTATION OF THE STANDARDIZATION PROGRAM TO DATE
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1 - Applications for 23 preliminary design approvals have been submitted for l review under the reference system concept. Preliminary design approvals have been issued for 13 of these designs; one application is still under i
review; and the nine remaining applications have been subsequently withdrawn i l by the applicants. All of the preliminary design approvals that have been j issued have since expired.
i . Applications for construction permits for 25 units referencing five of i the preliminary designs have been submitted for review. Construction permits j have been issued for 18 of the units referencing three of the preliminary i designs. The applications for the seven remaining units have been subsequently j withdrawn by the applicants. ;
- Applications for two final design approvals have been submitted for ,
review under the reference system concept. Final design approvals have been !
1 issued for both of these designs, however, compliance with the requirements.
I for new plant designs as set forth in the Commission's " Policy Statement on
! Severe Reactor Accidents Hegarding Future Designs and Existing Plants" (50 :
1 FR 32138) must be demonstrated prior to the issuance of a construction
- permit for an application referencing these designs. ,
i - Applications for operating licenses for four units referencing one of the
! final designs have been submitted for review. An operating license has been i i issued for one of the units; decisions on the issuance of operating licenses !
! for two of the units are awaiting the completion of their construction; and ,
i the review of the application for the remaining unit has been deferred at j the request of the licensee.
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I - Applications for construction permits for.15 units have been submitted I l for review under the duplicate plant concept. Construction permits have ;
been issued for 12 of the units, and the applications for the remaining three units have been subsequently withdrawn by the applicant. Seven of .
the units with construction permits have been subsequently cancelled. :
Applications for. operating licenses for six units have been submitted for
- review under the duplicate plant concept. Operating licenses have been
- 1ssued for three of the units, and decisions on the issuance of operating ~
1 licenses for the three remaining units are awaiting the completion of their construction.
- l' Applications'for construction permits for six units have been submitted ;
i for review under the replication concept. Construction permits have been .
issued for four of of the units. The applications for the two remaining units have been subsequently withdrawn by the applicant. Two of the units ,
- with construction permits have been subsequently cancelled. Applications t
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for operating licenses for two units have been submitted for review under !
j the replication concept. These units have been subsequently cancelled. ;
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2-
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- An application for a manufacturing license for eight units has been submitted for review under the manufacturing license concept, and the manufacturing license has been issued. Applications for construction permits for two units referencing the design hcVe been submitted for review. These applications have been subsequently withdrawn by the applicant.
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ENCLOSURE 3
SUMMARY
OF SIGNIFICANT PROPOSED REVISIONS TO THE COMMISSION'S 1978 STANDARDIZATION POLICY STATEMENT
- 1. Licensing Requirements for New Plant Designs The Comission's licensing requirements for new plant designs, both standard and custom, are set forth in its severe accident policy statement. These requirements are sumarized below:
Demonstration of compliance with the procedural requirements and criteria of the current Comission regulations, including the Three Mile Island requirements for new plants as reflected in the construction permit rule, 10CFR50.34(f);
- Demonstr'ation of technical resolution of all applicable Jnresolved safety issues and the medium- and high-priority generic safety issues, including a special focus on assuring the reliability of decay heat removal systems and the reliability of both AC and DC electrical supply systems;
- Completion of a probabilistic risk assessment (PRA) and consideration of the severe accident vulnerabilities that the PRA exposes along with the insights that it may add to the assurance of no undue risk to public health and safety; and
- Completion of a staff review of the design with a conclusion of safety acceptability using an approach that stresses deterministic engineering analysis and judgment complemented by PRA.
All applications for design approvals under the reference system concept, applications for construction permits, operating licenses, and combined construction permits and operating licenses under the duplicate plant ard replicate plant concepts, and applications for manufacturing licenses under the manufacturing license concept must address these four licensing requirements as set forth in the Comission's severe accident policy statement.
- 2. Design Certification through Rulemaking .
Although Appendix 0 to 10 CFR 50 provides the opsortunity for the Comission to approve a reference system design in a rulemacing proceeding, no one has taken advantage of that opportunity to date. This approach can contribute significantly to the stability of the licensing process. To further encourage the use of this approach, the Comission has outlined in its severe accident policy statement a design certification option for approving a reference system design. Under that option, a design certification would be issued by the Comission for a reference system design following the completion of a rulemaking proceeding. Because of the more rigorous reviews to which these designs would be subjected, design certifications will be issued with terms of ten years. Further, since the design would be approved by the Comission following the completion of a rulemaking proceeding, it would not be subject to litigation in individual license applications that referenced the design.
- 3. Changes to Approved Designs We believe that standardization will be best served if changes to approved or certified designs are minimized. Nevertheless, we recognize that there are situations in which such changes are needed or desirable.
Backfitting is defined in 10 CFR 50.109 as the modification of or addition to systems, components, or design of a facility; or the design approval or manufacturing license for a facility; or the procedures or organization required to design, construct or operate a facility; any of which may result from a new or amended provision in the Commission rules or the imposition of a regulatory staff position interpreting the Commission rules or the imposition of a regulatory staff position interpreting the Comission. rules that is either new or different from a previously applicable staff position after the date of issuance of the design approval under Appendix M N or 0 of Part 50.
The draft policy paper clarifies how the backfitting rule should be applied to each of the four concepts. As stated in the rule, the Comission will require backfitting of a facility only when it detemines, based upon the analysis required in 10 CFR 50.109(c), that there is substantial increase in the overall protection of the public health and safety or the common defense and securtiy to be derived from the backfit and that the direct and indirect costs of implementation for that facility are justified in view of the increase protection.
For the reference system concept, the backfitting rule applies after the issuance of the initial design approval, i.e. PDA or FDA.
For the duplicate plant concept the backfitting rule applies after the issuance of the initial duplicate design approval, i.e., PDDA or FDDA.
For the replicate design cencept, the backfitting rule applies after the date of the initial CP or OL for the base plant.
For the manufacturing license, the backfitting rule applies after the issuance of the first manufacturing license, i.e., based upon preliminary design information or final design information.
Holders of design approvals or certifications may modify the approved or certified design by applying for an amendment to the design approval or certification. Any such amendments will only be required to apply to applications for construction permits, and combined construction pemits and operating licenses that are submitted after the amendment is issued unless the modifications provide a substantial increase in the overall protection of the public health and safety or the comon defense and security.
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- 4. Overlap Between Duplicate and Replicate Design Concepts The Connission's 1978 standardization policy statement pemitted duplicate plant designs to be referenced in license applications docketed between the docketing date of the initial application referencing the duplicate plant design and a date five years after the staff approval of the duplicate plant design. It also permitted license applications for replicate plant designs to be docketed within three years of the dates of issuance of the staff safety evaluation reports for the base plants. We believe this overlap is unnecessary; applicants wishing to reference duplicate plant designs subsequent to their approval could do so without penalty under the replicate plant concept provided the three-year referencability period for the replicate plant concept were extended to five years. Therefore, future duplicate plant derigns will be permitted to be referenced in license applications docketed between the docketing date of the initial application referencing the duplicate plant design and the date of approval of the duplicate plant design, and future replicate plant designs will be pemitted to be referenced in license applications docketed within five years of the dates of issuance of the staff safety evaluation reports for the base plants.
- 5. Fees To further encourage the use of the reference system concept, we believe that fees that would otherwise be required of reference design applicants should be allocated among the applicants for permits and licenses which ,
propose to use the reference design. Accordingly, we would not require application filing or issuance fees for reference design approvals or certifications, or amendments or renewals thereof. If no application for i a permit or license for a facility is filed within the initial term or renewal period of the design approval or certification, any outstanding fees will become imediately due and payable by the holder of the design approval or certification.
Allocating fees among the applicants for permits and licenses who use a reference design is consistent with the draft " Nuclear Power Plant Licensing and Standardization Act of 1985." It should be noted, however, we have been informed by the Office of the Executive Legal Director that approval of the draft Act would be required prior to the Comission adopting this approach. Enclosure 6 to the Comission paper provides a discussion of license fees related to the reference system concept.
Fees for the other standardization concepts are those required by 10 CFR 170 for the type of license being requested.
I
- 6. Renewals of Reference Design Approvals and Certifications
We believe that the standardization policy statement should include provisions for the renewal of final design approvals and design certifi-cations but, in order to provide incentive to holders of preliminary design approvals to proceed with the development of final designs in a timely manner, preliminary design approvals may only be renewed upon a showing of good cause. Accordingly, not less than one year or more than three years prior to the expiration of the final design approval or the design 1 certification, holders of the approval or certification may apply for the renewal thereof. The approval and certification will be renewed for an additional period of time of not more than five years in the case of final design approvals, and not less than five or more than ten years in the case of design certifications provided the designs compi, with the Commission's current regulations. If no application for a permit or license for a facility is filed within the renewal period, any outstanding fees will become due and payable by the holder of the reference design approval or certification.
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ENCLOSURE 4 t 7101 Wisconsen Avenue l*~.
- emhoods uo 20 14-ce:s Telephone (301)654 9260 TWX 71os249602 ATOMIC FOR DC l ,
i November 1, 1985 Mr. William J. Dircks 4 Executive Director for Operations !
l U.S. Nuclear Regulatory Commission '
{ Maryland National Bank Bldg., #6715 4
7735 Old Georgetown Road
, Bethesda, Maryland 20814 !
i
Dear Bill:
l l
1 l In my May 30, 1985, letter to you, I alerted you to the formation of i an executive level AIF Study Group on the Practical Application of ,
- Standardized Nuclear Power Plants in the United States and of our j i intent to provide input to you in your efforts to update the NRC
- Policy Statement on Standardization.
i Since then our Study Group has met four times and has made iterative
! reviews of the work products of two very active working groups, our ,
Working Group on Regulatory Interactions, chaired by Mr. James i
Rhodes, Vice President Virginia Power Compa'ny, and our Working !
, Group on Design Information Requirements, chaired by Mr. Richard '
Priory, Vice President of Duke Power Company. The combined efforts of these groups are reflected in our enclosed " expanded outline" on ;
the Policy Statement on Standardization which we request you incorporateinthedevelopmentofyourholicyStatementrevision.
The concepts included in the enclosed " expanded outline" were also ,
t recently endorsed by our Policy Committee on Nuclear Regulation f
- chaired by Mr. Wallace Behnke, Vice-Chairman of Commonwealth Edison l Company. The enclosed document reflects the collective judgement of i
! the industry and demonstrates the high level of interest in [
achieving a workable standardization process. -
t t
Sincere , ;
l I
l l . Ward, Chairman
! AIP Study Group on the Practical ,
! Application of Standardized Nuclear L l Power Plants in the United States l l
JIN:wbb !
, cc: Chairman Palladino
. Commissioner Asselstine
! Commissioner Bernthal r Commissioner Roberth l
Commissioner Zech I
,, )N 10/31/85 POLICY STATEMENT ON STANDARDTZATION (EXPANDED OUTLINE)
I. INTRODUCTION Introductory section stating the purposes of the policy state-ment and the Commission's endorsement and encouragement of standardization.
Language from the proposed legislation would be included indicating that the use of standardized designs can benefit the public health and safety by concentrating the resources of designers, engineers and vendors on particular approaches, by stimulati.ng standardized programs of construction practice and quality assurance, by improving the training of personnel, by fostering more effective maintenance and improved operations, and because the use of such designs will permit a more effective licensing and inspection process.
The Introduction would explain how standardization will benefit the regulatory process by allowing a more expeditious and efficient review of the applications and a better understanding of the designs by the staff. The Commission would be asked to commit to a more disciplined review of standardized 11 ants, and not to allow the staff to re-review applications wit' tout due cause and authorization. The need for a well-defined review process would be emphasized, and mention would be made that the staff is cooperating with EPRI and others in the preparation of review guidelines to be used on standard design applications.
This section would indicate that this policy statement will apply to current LWR designs as well as variations of these designs; that it updates, ex7 ands, and replaces previous policy statements on the sub t' tat it is independent of any proposed legislation; ject; and that it will lead to the necessary amendments of appropriate NRC regulations.
This section would indicate that the standardization and licensing reform legislation, presently under consideration in Congress, is not in conflict but in direct support of this policy statement. The Commission believe,s that both a Congressional mandate and this policy statement, and resulting regulatory changes, are necessary to accomplish all of its goals regarding standardization and licensang reform.
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II. BACKGROUND This section would provide a brief history of standardization, with reference to the 1972 and 1978 policy statements, 10 CFR Part 50 Appendices M, N and O, PDAs and FDAs issued, and other applications processed under the umbrella of standardization,
] e.g., replicate, reference and duplicate plants.
III. RECENT NRC ACTIONS This section would summarize recent actions taken by the Commis-sion paving the way for new applications, e.g. , completion of TMI-related requirements, emphasis on the resolution of generic i issues, backfit rule, policy statement on severe accidents (SAPS *), ongoing work on source terms, and safety goal.
The purpose of this s.ection is to provide the bases for the positions- stated below and the Commission's endorsement of new applications. On the basis of the available information and -
the experience gained from the operating plants, the Commission has concluded in the SAPS that existing plants pose no undue risk to public health and safety. Language would be included l indicating that standard designs will not be subject to unnecessary changes by the Commission, and emphasizing the Commission's commitment to provide regulatory stability.
Reference would also be made to the legislation proposed by the Commission that would allow one-step licensing.
IV. COMMISSION POLICY
! Reference System Concept This section would update the corresponding section in the 1978 i
Policy Statement, and would eliminate the difference between the FDA-1 and FDA-2. It would also indicate that, based on th'e
- SAPS all current FDAs, and those to be granted in the future, may be referenced in applications for a Construction Permit 3 (CP) or Operating License (OL), or combined CP/0L.
!
- SAPS - Policy Statement on Severe Reactor Accidents
! Regarding Future Designs and Existing Plants, l July 30,1985.
I 2-
- s s, i I Preliminary Design Approvals This section would update the corresponding section in the 1978 Policy Statement taking into account the guidance contained in the SAPS (summarized in Section V of this policy statement).
3 '
Accordingly, after a PDA is docketed, the preliminary design s may be referenced in new CP applications, with the corresponding OL applicatien r6f erencing the approved final design. The SAPS contains criteria and procedural requirements expected to be satisfied by new designs. before they are granted final approval 1 or certification. However, PDA applications will be expected
_ to address thesescriteria and procedural requirements to the
, extent that it is reasonably possible. For example, although the Commission has indicated in the SAPS that it expects PRAs to be part of~3the PDA application process, it will not be a prerequisite for issuance of the PDA. If a comprehensive and detailed.PRA is not performed, a meaningful, limited quantita-tive risk analysis would be expected instead, either,as part of the PDA process or of th CP applications referencing the design. -
PDAs will be issued following completion of the staff's (including ACRS) review and would be subject to challenge in individual licensing hearings.
The discussion in the 1978 Policy Statement regarding the requirements for extending the life of PDAs active at that time would be eliminated as there are no PDAs active at this time.
Instead, this section would indicate that in the future PDAs will be issued for a term of 10 years.
Final Design Approvals This section would update the corresponding section in the 1978 Policy Statement taking into account the guidance contained in the SAPS (summarized in Section V of this policy statement),
and eliminating the difference between the FDA-1 and FDA-2.
' As in the.past, a PDA will continue no't to be a prerequisite for an FDA 'with applicants having the option to submit FDA-level Information-initially and proceed directly with an i
FDA revi ew. The FDA may be referenced in OL applications which had made reference to the corresponding PDA at the CP stage '
and may be referenced also in new CP. applications (and combined CP/0L applicatl,ons). .,-
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I The SAPS contains criteria and procedural requirements expected
- to be satisfied by new designs before they are granted an FDA.
If the scope of the FDA reference design application is limited 1 to an extent that would preclude the completion of a meaningful, comprehensive PRA, the requirement for a complete PRA may be waived. However, the applicant should still perform and submit
- supplementary risk analyses, to the extent practical, to demon-strate the adequacy of the proposed design. If a comprehensive PRA is not submitted for an FDA, an OL or combined CP/0L, '
applicant referencing the approved design would be required to submit a plant-specific PRA.
FDAs will be issued following completion of the staff's
- lincluding ACRS) review and would be subject to challenge in
- individual licensing hearings.
4
- This section would also indicate that in the future FDAs will l be issued for a term of 10 years.
h Duplicate Plant Concept t This section would update the corresponding section in the 1978 Policy Statement taking into account the guidance contained in ,
l the SAPS (summarized in Section V of this policy statement), '
i and eliminating the difference between the FDDA-1 and FDDA-2. ,
i
- As indicated in the 1978 Policy Statement, the staff will issue ,
l' a PDDA if the reference design is only preliminary, or an FDDA, '
if it is final. PDDAs and FDDAs will be issued following
- completion of the staff's (including ACRS) review and would be subject to challenge in individual licensing hearings. PDDAs FDDAs may be
- may referencedbe referenced in OL applications only in CPwhich applications;de had ma reference to the
i To be consistent with the previous sections of this policy
- statement and the SAPS, this section would indicste that PDDA i applications will be expected to address the criteria and
! procedural requirements described in th'e SAPS to the extent
- that it is reasonably possible. Accordingly, PRAs will not be j a prerequisite for issuance of the PDDA. However, if a r j comprehensive and detailed PRA is not performed, a meaningful, '
limited, quantitative risk analysis would be expected instead '
either as part of the PDDA process or of the CP applications ,
j referencing it. The criteria and procedural requirements i
contained in the SAPS will need to be satisfied before issuance of an FDDA.
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] This section would also indicate that in the future PDDAs and t
FDDAs will be a11 owed to be referenced in applications for r
periods of 10 years from the date of. issuance.
Manuf acturing License Concept This section would update the correspSnding section in the 1978 Policy Statement taking into account the guidance contained in ;
the SAPS (summarized in Section V of this policy . statement).
r To be consistent with previous sections, the 1978 Policy Statement would also be changed to require the design to be updated 10 years, instead of 5 years, after its approval.
Replicate Plant Concept This section would; update the corresponding section in the 1978 Policy Statement taking into account the guidance contained in the SAPS (summarized iri Section V of this policy statement). ,
- As indicated in the 1978 Policy Statement, when an applicant i
- proposes to replicate a 'previously approved -plant the staff a
would need to determine whether the base plant may be replicated, and theidesign would be subjec~t to challenge in individual licensing hearings. Applications for replication would be accepted for periods of 10 years following issuance of the SER for the base plant.
l To be consistent with the previous sections of this policy statement and the SAPS, this section would indicate that the criteria and procedural requirements contained in the SAPS would need to be satisfied before a design is accepted for replication.
I If the scope of the design to be replicated is limited to an extent that would preclude the completion of a meaningful, comprehensive PRA the requirement for a complete PRA may be i waived. However, ' plant-specific PRAs would be required from applicants referencing the design. .
StandardDesigndertifications This section would formally establish the concept of Standard Design Certifications. >
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As indicated in the SAPS, the Commission is in favor of offering Standard Design Certifications in addition to the PDA and FDA options. The PDAs and FDAs are issued following completion of the staff's (including ACRS) review and would be subject to challenge in individual licensing hearings. cps and ,
OLs based on standard design approvals would be subject to any design changes arising from their particular licensing pro-ceedings in accordance with the Commission's backfit rule. The Standard Design Certifications would be issued by the Commission following rulemaking individual hearings. proceedings and could not be challenged in To be consistent with the proposed legislation, a standardized plant design or "any major subsystem which represents a discrete. element" of the facility would qualify for a Standard Design Ce'rtification following the staff's final design review and approval. The Commission would also indicate its intent to provide t'he opportunity for a hearing as part of the rulemaking proceeding for a Standard Design Certification. As a result of this hearing Commission's,backfit rule.the design may be changed subject to the Standard 10 years Design Certifications would be issued for a period of combined,CP/0L applications).and may be referenced in CP or OL applications (o (The concept of design certification via a rulemaking proceeding described above is consistent with the SAPS. The proposed
' legislation uses the term " approval" instead of certification, and would empower the Commission to issue such approvals by means other than rulemaking.)
Level of Detail in Standard Design Certification Applications Critical to the success of the Commission's standardization policy is the level of information that must be provided in standard design applications. This section would encourage the industry to collaborate with the staff to develop guidelines similar to those currently available for CP and OL applications.
The Commission would emphasize the need for " essentially com-plete" design information in applications but would stress that i
! the applications should describe what is needed, i.e., methods, L procedures, and performance criteria, rather than specific pieces of equipment. The guidelines should be consistent with recent Commission emphasis on regulations that are less pre-scriptive and more performance oriented, and would incorporate some of the characteristics of the SDA concept discussed in the 1978 Policy Statement. (The proposed legislation indicates that R-1
l standardized designs should be "sufficiently detailed and complete to support licensing.") These guidelines will also need to describe the inspections and tests that would be necessary to ascertain that construction was completed in accordance with the design specifications.
Applicants will provide sufficiently detailed criteria to enable the NRC to complete the safety review of the facility.
The document provided by the applicant, a Plant Safety Report (PSR) or Standard Design Report (SDR) depending on the type of license requested, would describe major portions of the facility.
Design Criteria and Documentation To fulfill the NRC need for design detail, the report should define. the major design components and include the results of preliminary engineering to identify:
Design basis criteria Analysis and design methods Functional design and physical arrangement of auxiliary, BOP, and NSSS systems Plant physical arrangements sufficient to accommodate systems and components Functional / performance specifications for components and materials sufficiently detailed to become a part of associated procurement specifications Acceptance / Test Requirements PRA Methodology Required design documentation for systems, structures and components must include sufficient information to enable the NRC to make the safety determination and should include as appropriate:
Design basis criteria Plant general arrangements of structures and components Process and instrumentation diagrams Control logic diagrams '
System functional descriptions Component and procurement specifications including acceptance tes, requirements Construction and installation specifications QA program Emergency plans l
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Supportihg design documentation such as site data and calculations sufficient to support the above level of design detail Security ALARA/ Radiation Protection ,
Accident Analysis Draft Technical Specifications PRA It should be noted that all designs prepared prior to equipment purchase are subject to refinement and completion once detailed vendor information is available. From a conceptual and perfor-mance standpoint these details should not prevent the NRC from completing their health and safety determination. However, to deal with this situation without subsequent licensing proceed-ings, a program of confirmatory audits, performed by the NRC, could be utilitized to review the refinements to detailed design information which are necessary in the process of procurement and installation of plant components.
Probabilistic Risk Assessment ,
To complement the design criteria, a probabilistic risk assess-ment (PRA) should be prepared as part of COL applications to identify significant contributions to risk in the design.
Except in a few cases, the evaluation of component failures or equipment outages have been based on generic data, therefore, it is not necessary to commit to equipment purchase before performing the PRA. The completion of a PRA with adequate
, consideration for major risk contributors will increase the
! assurance that the design presents no undue risk to the public health and safety.
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, Acceptance / Test Requirements Licensees and their suppliers should define acceptance / test criteria to assure that designs are properly translated and correctly installed in the plant. These requirements should be defined early in the licensing process and implemented in a series of readiness reviews based on completion of construction and acceptance / test criteria developed during the design stage.
Changes to Standard Designs This section would indicate that standard design approvals and certifications will not be changed unless the Commission ,
determines, based on significant new information, that a l l
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, modification is required to protect the public health and safety, and in accordance with the backfit rule. In imple-menting the backfit rule, Appendices M, N and 0 to 10 CFR Part 50 will be revised to indicate that the cost-benefit analyses will be performed on the first or lead unit for the given standard design. If the backfit can be justified on the lead i unit, it will be implemented on all subsequent units referencing that design. If the backfit cannot be justified on the lead unit, it will not be applied to any unit referencing that design.
The backfit rule becomes effective after "the date of issuance of the design approval under Appendix M, N or 0" to 10 CFR Part 30 For designs going through different levels of approval,
- e. ., a PDA followed by an FDA, the backfit rule will be con-i si ered in effect after the issuance of the first approval, in ,
the same manner that a custom plant triggers the backfit rule ;
after the issuance of the Construction Permit. For desiggs -
- applying directly for a final approval, e.g. , an FDA without a i PDA, the Commission will institute a process by which the applicant for a standard design approval or certification would t submit to the NRC prior to the submittal of the application a complete list of regulations and staff guidance documents ,
(i . e. SRPs, Reg Guides, BTPs etc.) applicable to the design.Cl) p This list will be acknowledged in writing by the staff and will serve as the basis for the review of the design. Changes to these requirements and guidance will need to be reviewed and i
i approved by a high. level of management (possibly in a process similar to that followed by the CRGR) and documented in l writing. The purpose of this process is to provide discipline and stability to the review of standard applications even before the backfit rule becomes effective, and to serve as an
- incentive to the industry to develop the more detailed applications needed for a final approval.
l l i Once a Standard Design Certification has been issued, it will not be subject to challenge in individual licensing hearings.
Any challenge to the Standard Design Certification, whether sought by reason of special circumstances or otherwise, will I
only be considered in a rulemaking amendment procedure. -
(
l (1) Current regulations - 10 CFR 50.34(g) - require that applications for a construction permit, manufacturing license, and PDA or FDA be evaluated against the SRPs in ,
effect six months prior the docketing date.
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' This section would also indicate that the Commission recognizes the need to allow standard design holders and utilities to make changes in order to incorporate such considerations as new technical developments, improvements in the reliability or safety of the designs, or to make accommodations for mainte-i nance, radiation protection or procedural practices at a given
. utility. For example, a utility with other operating nuclear power plants may want to change the design of the control room in a standard design plant in order to maintain common features with the control rooms an its other plants. Similarly a standard design holder may want to incorporate new technical advances that may improve the performance of the design and thus increase its market appeal.
Changes requested by the holders of standard design approvals
~or certifications, if approved, will apply only to applications referencing the affected standard design and submitted after
, the change has been approved. Amendments to Standard Design
- Certifications would result in rulemaking* proceedings and the opportunity for hearings.
Changes requested by CP and OL holders, and holders of a combined CP/0L, that referenced a standard design approval or certification will be approved by the Commission if it determines that they are in compliance with the appropriate regulations. Such changes would be limited to the license (s) for which they were requested. Changes to operating licenses and deviations or variances from Standard Design Certifications (exceptions from a rule) may result in the opportunity for a hearing.
I Other changes may not re I
with 10 CFR Part 50.59. quire Commission approval in accordance Renewals of Standard Design i=
As indicated in previous sections, approvals for duplication '
i and replication, and all standard design approvals and certifi-i cations would be valid for 10-year periods. The 1978 Policy
, Statement established life terms of 5 y' ears for the PDAs and FDAs, and for the duplication and replication options. These periods were selected considering the number of plant license i applications anticipated at the time, the experience of changes i in safety requirements that were then occurring with time, and the relative newness of the concept. However, it is now
' apparent that, because of the prevailing depressed market for nuclear plants, the period of effectiveness used to date for the different standardization options limit the ability of
9 participants in the overall design of a plant to develop their portions of the plant designs well before the approval for an architect-other sections of the desi n terminate (e.g engineerdevelopingthebafanceofplant desIgn to mate with an approved nuclear steam supply system design), and thus obtain a reasonable return on investment by use of the design in one or more ?lants. Considering these factors, the current low order rate for -nuclear plants, which effectively reduces the number of units likely to use a specific standard design, and the significantly increased stability in licensing requirements expected in the future, the Commission considers it appropriate to extend to 10 years the life terms of all standardization options.
In addition, this section would indicate that holders of the j approvals and certifications described above may request renewals of such approvals and certifications prior to their -
expi rat.i on . The Commisgion, consistent with the intent of the proposed legislation, will renew the approvals or certifications "for an additional period of time not less than five nor more than ten years from the date of renewal."
V. COMPLIANCE WITH GUIDANCE IN POLICY STATEMENT ON SEVERE REACTOR ACCIDENTS REGARDING FUTURE DESIGNS AND EXISTING PLANTS On July 30, 1985 the Commission issued a Policy Statement on Severe Reactor Accidents Regarding Future Designs and Existing Plants (SAPS) containing the following criteria and procedural requirements that the Commission considers necessary for the
! licensing of new plants:
I a) Demonstration of compliance with the procedural require-ments and criteria of the current . Commission regulations, l including the Three Mile Island requirements for new plants as reflected in the CP Rule (10 CFR 50.34(f));
I b) Demonstration of technical resolution of.all applicable Unresolved Safety Issues and the medium- and high-priority Generic Safety Issues, including a special focus on assuring the reliability of decay heat removal systems and the reliability of both AC and DC electrical supply systems;
- c) Completion of a Probabilistic Risk Assessment (PRA) and consideration of the severe accident vulnerabilities the PRA exposes along with the insights that it may add to the
- assurance of no undue risk to public health and safety; and l
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d) Completion of a staff review of the design with a conclusion of safety acceptability using an approach that stresses deterministic engineering analysis and judgment complemented by PRA.
The SAPS indicates that it is the Commission's belief that a new design for a nuclear power plant can be shown to be acceptable for severe accident concerns if it meets these criteria and procedural requirements.
, In addressing criteria (b) and (c), the applicant for approval or certification of a reference design shall consider a range 1
of alternatives and combination of alternatives to address the l . unresolved and generic safety issues and to search for cost-effective reductions in the risk from severe accidents.
It is intended that a new design would satisfy each of the fundagental criteria listed above before final approval or certification. It is recognized, however, tnat a new design can go through different stages or levels of approval before this final approval or certification, i.e., a PDA followed by an FDA. The unique circumstances of each design review will, therefore, require flexibility in the application of the i
criteria listed in the SAPS. In particular the timing of the l PRA requirement may differ considerably from, one review to j another. In addition, the licensee is required to ensure that the intent of the safety requirements is accomplished during Procurement, construction and operation.
I A comprehensive and detailed PRA may not be achievable in the i
absence of essentially complete and final detailed design i inf ormation. Therefore, to require a complete PRA at the PDA l stage would not be realistic. The Commission's recent exper-lence, however, indicates that a substantial amount of design
! detail that would permit meaningful, limited, quantitative risk j
' analysis does exist at the PDA stage. Because the Commission believes that risk analysis of this type would be a useful .
l design tool, the Commission expects that it would be completed
, as part of the PDA application process. A complete risk t
analysis would not be a prerequisite for issuance of a PDA.
However, if this risk analysis is not performed in the PDA process, it will have to be provided as part of any CP
- application referencing the design.
i l If the scope of the FDA reference design application is limited to an extent that would preclude the completion of a meaningful, comprehensive PRA, the requirement for a complete PRA may be waived. However, the applicant should still perform and submit supplementary risk analyses, to the extent practical, to demon-strate the adequacy of the proposed design. If a comprehensive
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i PRA is not submitted for an FDA, an OL or combined CP/0L applicant referencing the approved design would be required to suimit a plant-specific PRA. For standard design approvals of restricted scope, additional limitations beyond the PRA aspects may exist.
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Note: This section is, except for some introductory and linkage words, an exact paraphrase of sections of the SAPS. .
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,1 g ,. APR 171985
- . ENCLOSURE 5' RULEMAKING OPTIONS FOR STANDARD DESIGN CERTIFICATIONS With its approval of the Severe Accident Policy Statement, the Confission has l
cleared the way for preceeding with the certification of standard designs by rulemaking. As the Comission is aware, the Policy Statement does not i require that a design vendor pursue certification beyond the staff's Final i Design Approval. The staff at present is uncertain whether vendors will ,
request certification by rulemaking, thereby removing from future licensing i
litigation issues regarding the adequacy of the design itself.1/ The staff believes, however, that vendors are more likely to consider sucE a step if the~ rulemaking procedures to be used have been clearly set out in advance.
To this end the staff describes below several alternative methods the Comission could choose to apply in a design certification rulemaking.
A. " Notice anh Written Coments '
~*
The" simplest procedure meeting the requirements of the Administrative Proce- --
dure Act is that used for most NRC rules: a notice of proposed rulemaking
- requesting written comments, review of the coments, and promulgation of a final rule. If this method, clearly the most expeditious, were adopted, the
- notice of proposed rulemaking would contain the following: (1) availability c of the application, staff SER, and Final Design Approval, and ACRS letters,
- together with other technical material supporting the application, (2) terms of the proposed proceedings, rule, i.e.,
(3) specific issues duration on which of certification, effect on (if coment is requested licensing any), (4 )
i role of the ACRS in the review process, and (5) the decisional criteria to be applied by the Comission.
Coments would be evaluated by the staff and the ACRS, with assistance from 4
the applicant as necessary. If substantial technical issues were raised which could.not be resolved on the basis of the existing application and SER,
- the applicant would be required to develop such information to support the -
1 application. This new infomation would have to be reviewed by the NRC staff l and might have to be made available for a second round of public coment if l'
it modifies the application in significant respects. A second round of notice-and-comment could obviously delay the issuance of a final rule substantially.
The initial resource investment for this method would be modest, both for the NRC and the applicant. This consideration might make this approach attractive to an applicant not wishing to comit substantial resources when j the market for the design is uncertain. As noted above, however, both the l
applicant and the NRC might have to commit additional resources
-1/ As the Comission is aware, GE has stated that it will not devote ,
resources to rulemaking at this time, but might consider doing so if a domestic order is received for a GESSAR-II plant.
_ . _ _. _ _ _ , _ , . _ _ _ . ~ . _ _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ . _ _ . . - . . . _ _ _ _ _ _ _
i The Comissioners - 2-to respond to public coments and to support a second round of publjc coment in some circumstances. _
i B. Notice and Coment with Opportunity to Request Legislative Hearing In this approach a notice of proposed rulemaking would be published requesting written comments as in (A), but would offer the opportunity of a legislative hearing upon request of an interested person or persons. As a
> condition to granting such a request, however, the requesting persons would be tequired to state what issues they wished to be considered at the hearing, j and comit to providing expert testimony on those issues.
If a hearing request were granted, notice of the hearing would be published in tlie Federal Register, setting out the details of the procedures to be -
r- - fpl)cred and. issues to be considered. (Although not an adjudicatory hearing, this process would be very similar to an operatin -
opportunity for hearing, notice of hearing, etc.)g The license Comission notice has the of
- discretion to employ a number of formats, from the simple hearing and re-
< cording of testimony to interchanges among those present and a limited right
. of cross-examination. Since such rulemaking procedures go well beyond the minimum notice and coment requirements for rulemaking, the agency has broad discretion to establish hearing procedures best suited to the matters at issue. .-
- Following such a hearing, the complete record of the rulemaking would be reviewed, including both the hearing record and any other written comments.
! The notice of final rulemaking would have to include responses to written comments- and the agency's resolution of issues considered at the hearing.
The resources needed to implement this option would obviously depend on whether one or more hearings were held. In the absence of a hearing, the -
resource comitment would be the same as for notice-and-comment. If a hearing were held, it is likely more issues would be raised in greater -
technical depth, and both applicant and NRC resources would be needed to resolve these issues and perform a thorough review of the hearing record itself. 2/ Given this potential for a larger resource commitment, this option mTght not be favored by an industry applicant in the absence of a clear domestic market for the standard design.
4 C. Notice and Coment with Hearings Absent Request 1/ In this regard, it would be important to impose some limitations on the scope and length proceeding at the outset. Absent any present limits on the hearing; it could easily grow to ECCS-size, i.e., 125 days of hearing and 22,000+ pages of transcript.
! ^
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The Comissioners - 3-This method goes somewhat further than (B) in that the notice of pr,oposed rulemaking would announce the agency's intent to hold infomal hearjngs on the proposed certification. The notice would set out the matters a't issue as specifically as possible, the hearing procedures to be used, and request that all persons wishing to participate in the hearings notify the agency within a stated period of time. Written coments would also be invited from those not .
intending to participate in the hearings. Hearing procedures would be '
flexible, as r,tated in (B).
\
l This approach would require a suintantial resource investment by the I applicant and the NRC. As with the previous alternative, it might not be ,
favored by a potential applicant where a definite market for the design did not yet exist. !
D. "On-the-Record-Proceeding -
= -
The agency has the option of conducting rulemaking by formal hearings, --
according to the requirements of Sections 556 and 557 of the Administrative Procedure Act. The procedure follows that for licenses, i.e., appointment of a hearing board, use of 10 CFR Part 2 Rules of Practice, fomal taking of evidence, including cross-examination, and board findings and recomendations to the Comission. The Comission retains final authority to accept or reject the board's recomendations in promulgating a final rule. Ia this
- . procedure the record consists onlymf evidence admitted at the hearing; written comments are not solicited or accepted from the general public.
This option would require the largest resource comitment from the applicant
-~ and the NRC. While the informal hearings associated with the previous two options-would tend to focus on technical issues, thus limiting the role and
, associated expense of legal counsel, the formal hearing requires full use of legal representation (in addition to the need for a adjudicatory board chaired by an attorney) to assure that the Rules of Practice are observed. -
We do not expect that this option would be favored by an applicant for a standard design certification under any circumstances.
! Role of the ACRS In each of the above options, ACRS views would be sought and considered.
ACRS review of the design should be performed prior to the rulemaking itself, l and the results of that review made available at the time the proposed rule is announced. The ACRS should be given an opportunity to review the complete l record (including coments on its own review) and a final ACRS letter on the l ' design 'should be forwarded to the Comission for its consideration during the final rule process. !
t The ACRS could, either by direction of the Comission or in its own dis-l cretion, hold one or more infomal public hearings on the design at which varying technical points of view could be heard. Such hearings would be more limited in scope than those suggested in Options (B) and (C) above, and w , w-w.-m<-.,w-w v -e-wv- -g w r- - ,-,~v ---+w-- ---,w.w. -,,-,-m,, ,*-ww >-vem=-=--~-e-%-w----w,--. .%e. ---w,-e-----w-e--v=---- - - - --- - - --,
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The Cam issioners - 4-I
! participation would most likely be limited to technical experts. Tb the extent non-industry groups wished to present expert testimony fosu(sed on technical issues, the ACRS could receive and evaluate such testimony, whether l written or oral. The ACRS would not be equipped to carry out general public hearings of the legislative type.
Advantages and Disadvantages Simple notice-and-comment rulemaking involves the least potential for delay (if time is an important factor) and the least initial investment of agency 4 and applicant resources. However, there may be a public perception that notice and comment without opportunity for any type of public hearing is not l commensurate with the significance of the outcome of the proceeding, viz.,
foreclosure of design-related issues for a period of up to ten years. The offeiing of an informal hearing could reduce the likelihood of legal ,
- - che,11enge by providing a broader forum for airing of public concerns.
. At the opposite extreme, formal rulemaking carries with it the greatest investment of resources and a large potential for an extended proceeding.
. The extensiveness of the record developed would give the agency a strong position as regards a substantive challenge to the rule in court (i.e., an assertion that the rule was not based on substantial evidence), but the requirement that Sections 556 and-557 of the APA be followed provides an arena for a variety of procedural-challenges (e.g., impermissibly restricting the scope of cross-examination). If experience is any guide regarding the progress of formal proceedings, a certification conducted by this method would probably take at least a year, with a potential for several years.
Counting from the issuance of the notice of proposed rulemaking, the staff believes the. notice-and-comment process could present a final rule to the Commission within six to eight months. This period could lengthen to a year -
or more if one or more hearings were held. The resource connitment for the agency and the applicant would depend on the scope of issues raised, the >
technical complexity of those issues, and the amount of work needed for -
resolution. To the extent possible, the applicant would be relied upon to perform technical work, subject to review and acceptance by the staff assisted by the ACRS.
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= - ENCLOSURE 6 LICENSE FEES Currently Part 170 requires full cost recovery (up to a ceiling of
$1,477,100) for review of standard reference designs for a nuclear power .
plant or major portion thereof when the review is conducted outside the context of a CP, OL or manufacturing license application. The fee is billed to the applicant at six-month intervals as the review progresses until the review is complete either by issuance of an approval, withdrawal or denial ~.
Prior to June 20,1984 (date current rule was adopted), Comission regulations required PDA review fees to a ceiling of $462,100 for each NSSS and BOP and FDA review fees to $533,400 for the NSSS and $551.200 for the BOP. The fees were to be paid in five installments based on payment of.20 percent of the approval fee as each of the first five i units of the approved design were referenced in utility applications.
Thirteen PDAs have been granted and none were subject to fees under Part 170. Two FDAs have been issued to date. Both were issued during the period of the 1978 fee schedule. Combustion Engineering has paid $436,720 of $533,400 in review fees for CESSAR-80 (NSSS) since it was referenced only four times. General Electric has paid only the application fee
($50,000) since the approved design has not been referenced in a utility application.
The fee proposal contained in the draft revised standardizatiori policy statement would not require an application fee or periodic payment of review costs for approval certification, amendment or renewal applications.
Fees designed to recover costs would be allocated among the applicants for cps, OLs and combined cps and OLs proposing to use the reference design. If no application for a permit or license for a facility is filed within the initial term or renewal period of the design approval or certification, any outstanding fees become imediately due and payable by the holder of the approval certification.
l.
The modification of fee requirements does not deal with the following issues:
! 1. The current NRC fee policy, based on court decisions, is that specific charges (fees) are assessed for specific services rendered to identifiable recipiants. Thus fees are assessed only to the applicant for the service.
Contact:
W. O. Miller, LFMS/ADfi 49-27225 l
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- 2. If the legal obstacle of charging costs to persons other than the applicant is resolved, the question remains as to how the costs are to be allocated. The court has warned that fee development and assessment must not be arbitrary and capricious.
- 3. The proposed requirement that the fee shall become immediately due and payable by the applicant for the design approval if no reference application is filed by a utility raises several questions; e.g.,
is it practical to bill for services perfonned after a 10-year lapse in time; what if the initial applicant for design approval is no longer in business; who is responsible for the costs if the
~
design application is denied or withdrawn, etc.
The applic.ation filed by Westinghouse Electric for RESSAR-SP/90 is currently dndergoing staff review and the applicant is subject to fees for full recovery of NRC costs to $1,477,100. Also, the review of the severe accident analysis report filed by General Electric for GESSAR II is nearing completion, and this amendment to the FDA-1 is subject to full cost recovery under Part 170. General Electric has filed a written
_ request to be exempted from the provisions of the revised rule for the GESSAR II severe accident analysis report. If granted, General Electric would not be required to pay any part of the FDA-1 fee unless it is referenced by utilities. -
If the Commission readopts a deferred payment schedule, fairness and equity would seem to dictate that deferred payment also apply to the applications currently on file.
~.
- 1. The $1,477,100 PDA for RESAR-SP/90 (which would include the cost for the review of the severe accident analysis) would be deferred until the approved design is referenced in a utility application (s) or the initial approval or its renewal expires.
- 2. The fee for the GESSAR-II severe accident analysis would be deferred l until the approved design is referenced in a utility application or
- the initial approval or its renewal expires.
The enclosure shows fees required under 1978 and 1984 schedules.
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Attachment:
Fees For Review of PDA, FDA l
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s FEES FOR REVIEW OF PDA, FDA .
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1978 Rule 1984 Rule Application Fee (NSSS. 80P) $50,000 $50,000 (preliminary, final) i PDA (NSSS) $412,100 (excludes appl. fee)* , $1,427.100 (excludes appl. fee)*
- PDA (BOP) $412,100 (excludes , appl. fee)*
FDA(NSSS) .. . $483,400 (excludes appl. fee)* $1,427.100 (excludes appl. fee)*
FDA (BOP) $501,200 (excludes appl. fee)*
Amendment to PDA, FDA Full cost Full cost
- Payment 5 installments for first 5 units Payment due at 6-month intervals referenced as work progresses
- Charge based on full costs to ceiling.
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? ORIGINAL ,
UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMMISSION r:
In the matter oft . ,
/
COMMISSION MEETING Briefing on Policy Statement on Nuclear Power Plant Standardization (Public Meeting)
Docket No.
Location: Washington, D. C.
Pages: 1 - 83 Date: Wednesday, December 11, 1985
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ANN RILEY & ASSOCIATES Court Reporters
( 1625 I St., N.W.
l Suite 921
"' ' ) Washington, D.C'i 20006
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(202) 293-3950 1
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1 D 1 SC LA I MER 2
3 4
5 6 This is an unofficial transcript of a meeting of the 7 United States Nuclear Regulatory Commission heid on J S 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 opinion 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 Commission may 21 authorize. ,
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1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 ***
4 BRIEFING ON POLICY STATEMENT ON 5 NUCLEAR POWER PLANT STANDARDIZATION 6 man J 7 PUBLIC MEETING 8 zum 9
10 Nuclear Regulatory Commission
! 11 Room 1130 12 1717 H 9treet, Northwest 13 Washington, D.C.
14 Wednesday, 11 December 1985 15 16 The Commission met in open session, pursuant to 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 22 JAMES X. ASSELSTINE, Member of the Commission l
23 FREDERICK M. BERNTHAL, Member of the Commission i
24 LANDO W. ZECH, JR., Member of the Commission l
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1 Presenters seated at the Commission Table:
2 William J. Dircks 3 v' i c t o r Stello ,
4 Frank Miraglia 5 Cecil Thomas 6 Sam Chilk i
? Hersel Plaine i
i i 8 1
. 9 Audience speaker:
10 William Olmstead 11 12 l 13 ,
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3 1 PROC E ED I NG S 2 CHAIRMAN PALLADINO: Good morning ladies and 3 gentlemen. Today we have with us members of the Stati to 4 discuss SECY-85-382, the proposed Standardisation Policy 5 Statement.
6 Early this year the Statt forwarded SECY-85-225, 7 which discussed the stait plans for formalising the subject 8 policy. This is our first meeting with the Statt on this 4 9 subject, i
10 In 1978 the Commission approved a standardisation 2
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.
1 14 Recently, the Commission issued its Severe Accidents i 15 Policy Statement which set forth licensing requirements for j 16 new plant designs.
, 17 In addition, the Commission has proposed to the i
18 Congress dratt legislation entitled Nuclear Power Plant 4
19 Licensing Standardisation Act of 1985 t
20 To supplement these actions, I believe it is 21 appropriate for the Commission to update the 1978 '
22 Standardisation Policy Statement to reflect recent NRC i
I 23 initiatives. _
24 At the completion of today's meeting, I would f
25 like to get a feel from my tellow Commissioners to determine i
4 I whether or not they feel they have enough information to act l 2 on SECY-85-382 in the near future, or whether additional 3 actions are needed. And it 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 Stait, do any of 7 my tellow Commissioners have any additional opening remarks at 3
8 this timet 9 COMMISSIONER ZECH: No.
10 COMMISSIONER ROBERTS: No.
11 COMMISSIONER ASSELSTINE: No.
12 COMMISSIONER BERNTHAL: No.
l 13 CHAIhMAN PALLADINO: All right. Let me turn the 14 meeting over to Mr. Stello.
]
15 MR. STELLO: Thank you, Mr. Chairman.
l 16 What we want to do this morning is to present to you l
1 17 the results of the stati's view on what the Commission ought 18 to adopt as a Standardisation Policy Statement.
19 There are two things that I think are important to 20 recognise in doing so. First is that we have had the benefit j 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 industryg the utility i
24 organisations, representatives from architect / engineering 25 firms and vendors to try to describe to the best of their
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1 ability what they thought was important as they saw the future
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2 of nuclear power, and what options they felt was important in 3 a standardisation policy that they thought were going to be 4 significant in revitalization of the nuclear industry.
5 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 8 we think, and where those differences are, and why we have 1
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
! 13 Statement does reflect that it is the Commission's desire and i
14 intent that for the long term some of these other options 15 would, hopefully, move by the wayside and you would have a t
16 true certified standardisation concept. And that is recognised 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 i
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 24 question on your interaction with the industry.
p 25 I understand the AIF ettert. We also had a fairly
)
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1 substantial submittal from EEI, and we had a presentation 2 about a year or so ago from EPRI.
3 MR. STELLO: Yes.
4 COMMISSIONER ASSELSTINE: In some respects it 5 rppears that the EEI and EPHI efforts were a bit different t
6 than the AIF effort, particularly in the aggressiveness to 7 which they wanted certain elements in the standardization; 9 namely more complete facility design.i 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? If those customers don't see what they 12 want from a standardization policy and from standard design, 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.
I 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 is 23 what is available. _
24 And they had a fair representation on the AIF I
25 committee, and I stressed particularly that it was especially l
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7 1 important for them to get that utility input because they 2 were, in fact, the customers and they would, in fact, determine i
3 the market. And what we have in the way of comments 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, because it then does 7 truly represent the utility industry view. It fell short of 6 that, but had representation of various members who are 9 associated with NUMARC.
10 COMMISSIONER ASSELSTINE: Is it your view the AIF 11 ettert is truly reflective of the EEI work and the EPRI work i 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 ccncept as a possibility, rather than in standardization. We i
16 are really talking about' starting from scratch in terts of 1
17 designing, not using existing designs, as much as the concept 18 that AIF telt 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 r e c,o r d .
23 COMMISSIONER ROBERTS: You bet. Replication. They
! 24 are not going to start from scratch with some new grandiose i
j 25 design. That's crazy.
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8 1 MR. STELLO: That"s the thing that they felt for the 2 next plaat 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
? 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 ut111ty 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 if 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 24 AIF, I think it was clear what the EPRI effort is. But
! 25 certainly, I think the EPRI effort would be consistent with
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.i 1 - dne of the concepts that is proposed in the policy statement, m
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 s -
5 short term.
A \%
6 I;think jn t. e discussions we had at the AIF, Commissioner.Asielstine, to respond to your last question, I
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think before a utility Executive would make a decision about 9 replication br duplication, they feel that this policy 10 statement would set tho' stage for that kind of decision base i t' t'o be met. And so, I think they see it as an important first 4
12 step towards those kinds of decisions.
13 CHAIRMAN PALLADINO: But I have a problem. Based on 14 what you tell me the industrf wants, I don *t understand why we 15 talk about not only an entire plant design, but standardizing 16 a portion thereof. ~
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17 It is my impression, and I didn't get it only in the 18 last five years, I n'a' ve had it for quite a while, that the 19 whole' plant isDan~ integrated system, and the interaction 20 beiween parts ofEthe plant, be it balance of plant or nuclear 21 steam supply system, 's i very importint in knowing whether or l '
, 22 not you have got a good reliable design. .
23 Why.do we talk about standardizing a_ major portion 24 ,
thereot --
a ,n d that is throUgnuut the whole document --
s ,
25 because if I hear the industry right, they would like to do l
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10 1 exactly what you said, build a plant for which they have a 1
2 complete design and whose characteristics they know well, and 3 that has some proven record of reliability.
- 4 MR. MIRAGLIA
- I think that 11 one looks at 5 standardisation and the implementation of it, since the early 6 '70s and through '78 and beyond, there was a clear distinction 7 between NSSS and balance of plant. And as we have come down 8 the path in time of implementation, the scope of the designs 9 being put before the Statt are certainly much broader. That 10 was particularly true in the sense of the GESSAR application 11 with the nuclear island, which was essentially the entire 12 plant except for maybe the turbine island, and in the 13 Westinghouse RESSAR review, that is also the case.
14 CHAIRMAN PALLADINO: So why should we perpetuate 15 that thinking?
16 MR. MIRAGLIA: Well, I think it has the options 17 there, whether people avail themselves of that option would i
18 remain to be seen. And I think it is also consistent with the 19 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 i
22 them in the policy statement.
23 11 one looks at the legislative package that we l -
24 sent --
25 CHAIRMAN PALLADINO: I haven *t looked at it lately.
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11 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. l 3 CHAIRMAN PALLADINO: Maybe that was a tailing of the 1 1 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 stil) 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
< l 11 might not be misleading people it we talk about standardising )
12 a portion of the plant, because these plants do have 13 interactive systems and components that very much attect 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 arp right. And it the reason that we .
18 are doing that here is because that is the way the legislation 19 'was worded, maybe we ought to rethsnk that because --
, \
' f 20 CHAIRMAN PALLADINO: I*11 have to go back and reread 21 the legislation. I haven *t read it in a whilea 22 MR. STELLO: I think there are some underlying 23 reasons about the structure that we have, in the industry that y
24 causes that to happen, tco. You have,had historically the 3
> 25 tour major nuclear steam suppliers,'bho were looking at waysi I
i l
. . L- . -
12 1 in which to standardize their portion of the plant. And they s
2 started to come in. )
3 Now, when you have that portion of the plant 4 standardized, and then you have a much larger number of 5 architect / engineers who want then to get into the balance of 6 plant design, and come in with what they consider the balance 7 of plant design that was standard for any one of those four 8 different suppliers, we are talking about a fairly large 9 number of combinations that were possible, t
10 Now, it is more ditticult in the interface problems 11 in terms of trying to describe the nuclear island or smaller 12 portion of a plant in terms of nuclear steam suppliers' end of 13 the-business. But it was necessary because that is the way 14 they were, in fact, going about conducting their business.
15 That is the portion of it they were selling, and they were 16 st adardizing that portion that they were selling, which is a 17 good. idea.
18 And you had that being a standard package ottered 19 to anyone who is going to build a plant. And at least that 20 portion of it you had fairly high confidence that you knew 21 what was in it, you didn't need to go over and review that 22 over and over again. You had a fairly good basis for 23 concluding that you understood that portion of the design.
i 24 But that did not mean that when ycu then=got the 25 balance of plant designer in, that you had to look at the rest
e
= !
13 1 of it to make sure it would work out okay.
2 COMMISSIONER ASSELSTINE: That's an accurate 3 historical picture, I think. But I also think that that 4 identifies 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 then 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 ?0 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 NSSJ 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 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
, r-w i- -- ,, - w -
y,,-,w--+e-
14 I the industry --
necessary if they are going to be building 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 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 4
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.
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 specifications for the 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 ma es a transition 24 that one hopes is smooth, and in a nev4rtheless integral 25 package to specifications that can be fulfilled by the i
l
l
- l 15 I architeot/ engineer, by any of the various several 2 architeot/ engineers. I 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, though specified, would be tilled by various 10 architect / engineers.
I 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 l
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.
J 20 COMMISSIONER BERNTHAL: Can you answer me very 21 quickly, though,. institutionally, is that kind of what you 22 envision?
23 MR. S7ELLO: I think short answer, that is one et 24 the options.
25 MR. MIRAGLIA: And I think it is an accurate l
l
- l. . _ . __
. - ~
5G s .
1 representation, as Commissioner Asselstine said, of where wo 1
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.
4 5 Certainly, it one wants to take full benefit 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 CHAIHMAN 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 18 the presentation. But, Commissioner Roberts had a few --
19 COMMISSIONER HOBERTS: I had a question for Jim.
20 You said what we want in standardization. Would you 21 give me a definition of what ww want for standardization?
22 COMMISSIONER ASSELSTINE: What I would like to see 23 is a standardisation program that leads to the development and 24 use of a few, essentially complete, standardized designs. Not 25 one, but perhaps two or three standardised designs for this l
l t
i
o 17 i
1 country that when the utility comes in and says, we are ready 2 to start building the plant, the design is sufficiently 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 5 just a few basically complete standard designs.
6 I don *t think we can get to one, but I think we i
? 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 i
11 think it benefits both the regulators, the public and the 12 industry it 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 1
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 ditticulty in 22 supply that the utilities now face, the ditticulties in i
23 sources of supply for components, replacement parts, equipment, 24 difficulties in maintenance.
25 We would just be much better off it we could get to 1 -- - . __ _ , , , _ . , _ _ _ _ - . - . . -_ -. .
l 18 l 1 a tower number of essentially complete designs, get all the m
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.
q 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 i 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 I
2
, 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 1
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 i
! 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 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 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
$ have been talking much along the same lines.
6 COMMISSIONER ZECH: I feel very much the same. I
? think that we ought to listen to the Staff 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.
l 10 Mr. Chairman, I would suggest we let the Staff --
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 &nd 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 typear.
17 COMMISSIONER BERNTHAL: We'll probably learn more 11 18 we listen rather than talk.
19 CHAIRMAN PALLADINO: That's right. As I tell myself 20 once in a while, I ain't learning when I'm talking.
21 MM. .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.
t
20 1 Briefly the backgrouna of the standardization policy
T J l 2 and how it evolved over the last decade, the need for us l 3 taking some action and revising the existing policy statement 4 that is now on the record.
5 What present standardisation concepts we think 6 should be retained, and the reasons for rotatning those l
7 concepts, i
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 identify for 12 you the differences between what the'Statt was proposing and
- 13 what was in the AIF proposal that was enclosed as part of the 14 Commission paper on the sub}ect.
15 May I have the next slide, please.
16 [ Slide.3
, 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.
23 In August of 1974, that policy statement was revised l
24 to articulate an additional concept, which is the replicate 25 plant concept, i
21 1 In 1977, the Commission reattirmed its support for I
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.3 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 u*ilising 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 ci 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 be*--e 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 COMMISSIONER ASSELSTINE: Are there any replicates i 2$ that are still under construction? Active construction?
l t
l 1
22 l
1 MR. MIRAGLIA: To the best of my knowledge, no.
3
) 2 COMMISSIONER ASSELSTINE: It 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 --
9 COMMISSIONER AbSELSTINE: 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. MI2AGLIA: Duplicate is sort of a special case 25 --
23 1 COMMISSIONER ASSELSTINE: It is a custom plant where m
)
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.
? CHAIRMAN PALLADINO: Okay.
8 MR. MIRAGLIA: It is on the next slide. It I can go 9 through this one, I*11 get to that.
10 CHAIRMAN PALLADINO: I*11 wait. Thank you.
11 [ Commissioner Roberts left the room.]
12 MR. MIRAGLIA: In addition, since 1978, we have had
's
.s 13 various considerations on the severe accident policy 14 statement. And in that policy statement the Commission has I 15 articulated additional requirements that new designs should 16 consider; compliance with the current rules, regulations et j 17 the Commission, compliance with the CPML rule, technical ~
! 18 resolution of unresolved safety issues, and high priority 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 PRA to establish what the l
22 design basis for the new plants would be.
l 23 In addition, there is the proposed legislation that 24 also has certain concepts in it that sre related to the 25 standardization policy. That legislation was proposed, !
[
24 1 believe -- reproposed to the Congress in January '85.
N
/ 2 And that has the concepts of a combined CP-OL. It 3 had the incentive of waiving fees, set up a design approval l 4 process to consider ten years design certification process, 5 and it set a threshold for changes in that standardised 6 design.
? CHAIRMAN PALLADINO: Which one was this?
8 MR. MIRAGLIA: This is in the Licensing Reform Bill t 9 and the Standardisation Act of 1985.
10 And as a result of considering all of these, what 11 you have before you is a Staff proposal that represents our 12 current views on how these various pieces should be put
') 13 together to modify the existing policy.
14 Within the proposed policy statement we have retained 15 the present standardization concepts, the reference system 16 concept. And that is an application for approval or 17 certification of an entire plant or major portion of a plant
, 18 without having a specific application before us, a spectito 19 identified site.
- 20 It would be a design for a plant such as GESSAR.
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 24 plant, and that review is being conducted. There is not 1 25 specific application at which that design would be put on a
- - - - - , . - - - - - - - ,- ,.n-, ,,.n,-., .. -,,, - , , , - - .- ,m -
-m-,,
25 I site and be used at this point in time, m
l 2 A duplicate --
3 COMMISSIONER ASSELSTINE: Can you give us some 4 examples, then, of plants that have been butit using each of 5 these elements.
6 MR. MIRAGLIA: Sure.
7 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 i
12 GESSAR.
. 13 COMMISSIONER ASSELSTINE: Okay.
14 MR. MIRAGLIA: Those would be examples of a reference 1
15 system design.
16 Duplicate plant would be an application for licenses 17 for a number of plants of essentially the same design at l 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 b,een built under 23 that concept, you would have Calloway, Wolf Creek and certainly 24 Byron and Braidwood are duplicate plants. And Hyron is 25 licensed, and two Braidwood units and the additional Byron
26 0
1 unit is currently under review now.
2 CHAIRMAN PALLADINO: Why do you say at different 3 sites? What would be wrong with doing it at the same sitet ,
4 MR. MIRAGLIA: Well, essentially you have a 5 combination of both. Lyron 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 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?
, . -~s
) 13 MR. MIRAGLIA: No, sir.
l 14 CHAIRMAN PALLADINO: Well, this one says "of 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 ditticulty. The distinction seems 21 to be ditticult to follow because I don't understand --
22 MM. MIRAGLIA: The major differences come out when 23 one looks at the concepts, is determined in re orenceability 24 of tha various designs and the time at which the review was 25 conducted.
- 7 1 CHAIRMAN PALLADINO: No, I am trying to understand 2 duplicate and replicate. So, why don't you go ahead with I 3 replicate.
4 MR. MIRAGLIA: Replicate is an application for one 5 or more plants, essentially of a design that has already been 6 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 ditterence. Duplicate is --
13 COMMISSIONER ASSELSTINE: It is really timing.
14 MR. MIRAGLIA: It is the timing on the review and 15 the application.
t to COMMISSIONER ASSELSTINE: Duplicate they all come in 17 together. Replicate, you go back later on and say, hey, wo 18 want to build another one just like we built here.
19 MR. MIRAGLIA: Yes. The review is essentially 4 20 complete. You could come in f or a duplicate design while the 21 other review was ongoing, 22 CHA!NMAN PALLADING: Okay.
23 MR. MIRAGLIA: And the manutacturing lteense was a 24 specific application to miautacture a specified number of 25 identical plants at a location other than where the plant i
28 1 would be operated. And that was the floating plant concept, 1
2 which result '
in the utilisation 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 OLs.
7 COMMISSIONER ASSELSTINE: They have all been l
8 cancelled.
i 9 MM. MIRAGLIA: Jamesport and Marble Hill were 4 10 repiteates. 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.
i 13 CHAIRMAN PALLADINO: What was it?
. \
14 MR. MIRAGLIA: Jamesport. Long Island Lighting and l 15 Power.
16 May I have the next slide.
17 [ Slide.]
18 As I said, in developing the Stati proposal for the 19 policy statement that is now before you, we considered the 20 Severe Accident Policy Statement requirements, and the 21 legislation, i
22 And the elements that have been icided into this 23 policy statement that is different from the 19'8 policy 24 statement reflect those requirements that are in the Severe 25 Accident Policy Statement that I discussed earlier. i l
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 recognises the new backfitting considerations in the 6 rules, and that is clearly articulated within the proposed
? policy statement for each of the concepts.
8 This next point is a clarification of how one would 9 reference duplicate and replicate plant designs. The 10 timeirames for review were specified 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 11 statement, rather than to have the different timeirames, wo 16 have tried to clarity 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 live years.
21 The design approval is good for live years. And a plant could 22 he duplicated as long as the point of referenceability is --
23 CHAIMMAN PALLADINO: But If they build one of the 24 plants and then come later and want to --
25 MM. MINAGLIA: It would then become a replicate.
30 1 CHAIRMAN PALLADINO: It becomes a replicate.
s 2 MR. MIRAGLIA: Hight.
3 So, there was this contusion before as to what bin 4 it tell in.
a 5 COMMISSIONER ASSELSTINE: How long is the repiteation 6 period, and when does it run from? Replicate is tive years 7 trom the issuance of the SER on the base plant.
8 COMMISSIONER ASSELSTINE: So in terms -- 11 you 9 wanted to replicate, say, one of the SNUPPS plants, when would 10 the door close on that?
11 MR. MIRAGLIA: It would be tive years from the base l
12 plant, which I think turned out to be Calloway.
13 COMMISSIONER ASSELSTINE: Hight.
1 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 SEE on Calloway, 18 which was probably back in '83.
19 CHAIRMAN PALLADINO: Last supplement?
20 MR. MINAGLIA: I would say it would probably be
- 21 post-ACES supplement. After in* Statt has completed the I
f 22 review, it has been to the ACMS a ad we considered the comments, 23 that supplement there would be the date of reterenoeability for I
24 repiteation of that design.
25 COMMISSIONEM ASSELSTINE: So you can only repiteate
'1 h
31 1
1 a SNUPPS design for three more years 11 you didn't get in 9
/ 2 your application in two or three --
3 MR. MIRAGLIA: Two to three.
4 CHAIRMAN PALLADINO: Suppose somebody came in in the 1
] $ sixth year --
6 MR. MIRAGLIA: Mut I think in this policy statement 7 what we are saying is, for the transttson period the Commission 6 would be saying, 11ve years from the issuance of the policy ,
9 statement.
i 10 CHAIRMAN PALLADINO: But suppose somebody came in 11 after six years and said, I'd like to repiteate it. Do they 12 get categorically turned down?
4 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?
j 17 MR. MIRAGLIA: Well, in --
- i-
- 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, 4
22 and saying there is a need for this window for a period of l
I' 23 time.
. 24 We picked five years. The Commission could decide !?
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
) 2 reference plant concept and option, and going to the 3 essentially complete design.
4 CHAIRMAN PALLADINO: But you are getting S standardisation. You got another one that is the same as e something else that went before, 7 Now I can understand it we think it is no longer a 8 viable design because at some new teature that we feel ought 9 to be in. That is one thing.
10 MR. MIRAGLIA: And the policy statement does 11 recognise that these things would have to be looked at on a 12 case-by-case basis. Judgments would have to be resobed.
13 CHAIRMAN PALLADINO: I don't recall any escape 14 clause that says the Commission could grant exceptions. I 13 guess maybe there is a general exemption clause.
16 MR. STELLO: As I recall, we are going to allow an 17 extension up to tive years in the future. But, in all cases 16 they could tall back to a custom plant review and you could 19 approve it.
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 tall -- and you always have that case where you tall 24 outside of the standardisation polley statement, and you will 23 go into a custom review.
33 1 CHAIRMAN PALLADINO: Well, but it 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 5 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.
- MR. MIRAGLIA: I think the real basis is to encourage 9 and get to a meaningful transition to the overall objective is to to be along the lines as the Commissioners here discussed 11 today.
12 COMMISSIONEM NEMNTdAL: Mut the reason finally for a 13 cutoit date is very important it seems to me.
14 You out it oli after some period of time, whether 15 it is inve years or seven years is a matter ci policy 16 decision. !! you don *t do that, standardisation 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 eutoli 23 date.
24 MM. MINAOLIA: And as you said clearly it is 4 25 policy, and that is the balance that one is trying to --
34 1 CHAIRMAN PALLADINO: what I was trytng to seek, some 3
2 option whereby it 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 7 COMMISSIONER BERNTHAL: It it turns out that advances
- 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 justittoation, that certainly 13 could be done. And that could be brought to the Commission 14 saying l' 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 COMM1891CNER BERNTHAL: Normally -- that is why 1 18 feel so strongly that we have got tour polley statements that 19 interlock, and that are terribly important that they more or 20 less come out in coordinations safety goal and advanced 21 reactor polloy statement til into this hustness, it seems to 22 me. And it is very important that the Commission decide where 21 it wants reactor design to go both in terms of 'afety s and 24 progress, 25 You know, if you just sit there with a standardised
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 Iust 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
- 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 wculd have to go back to the previous position la on tees. The fee provision here is one, to be an inducement 13 that their toes could be waived consistent with the 14 standardisation legislation. But, it would require a 15 legislative change in order to enact that.
16 CHAIMMAN PALLADINO: I see. We een*t --
17 MM. MINAGLIA: Without the legislation we would have le to medity that provision to be consistent with the existing 19 fee schedules.
20 CHAIMMAN PALLADINO: Okay.
21 MM. MINAGLIA: Whleh would, I guess, not have the 22 same degree on induoement. There would be some partial waiving 23 of fees depending upon the number of applications that are 24 g 01.3 2 to reference the spooltto designs.
25 COMMISSIONEM ASSELSTINE: How do you tigure that out
36 1 as a practical matter, Jim? Here you have got a reference
) -
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, tive 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.
I 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 etteet prior to 1984
% 13 assumed there would be tive users. And you would allocate 20 14 percent to each of the tive as they came in.
l 15 We got into this situation a little bit because of 16 the proposed legislation. The language is almost identical i 17 And the Ottice of Administration has pointed out in your paper i
18 that this is something that we have to come to grips with 19 somehow.
20 Not only that quostlon, but ii no one reforences i(,
21 how we are authorised to go back and collect retroactive toes 22 from an applicant.
23 CHAIRMAN PALLADINO: Wut another way is to have the 24 designer pay the tee up trent, and then collect from the 25 customers themselves. I expect this is not a major traction 1
=
l 37 1 of the costs he is going to incur anyhow. However, I 2 undesstand the' Inducement.
3 MR.' THOMAS: However, within the current fee 4 structure, i t. is number of millions of dollars. Yes, in t
~
5 relationship to the up front commitment of the design, it is a 6 small point. -
7 COMMISSIONER BERNTHAL: I just wanted to compliment 8 you on what I thought was some creative thinking, and thinking 9 that exhibited a good deal of foresight in the suggestions you 10 have made here in design less allocations and whatnot.
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 l
13 started when nobody seems avilling to step forward right now
> 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 go t the b'll a rolling. Because, 11 I 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
! 21 market in the end, at the end of ten years, I guess, falls on s
22 the vendor.
23 I think it is a good idea. It is a reative 24 approach. I compliment you on the concept 25 MR. MIRAGLIA: It is a very small carrot, as the
- , - - - , - _ _ - , v, -. - . - . - , - , _ , . - . - . . _, 3 -
. 38 1 Chairman points out.
2 MR. STELLO: The industry brought up the issue of 3 who would come forward with certification. The major problem 4 is, where are they going to get the funds to support the 5 design effort necessary, which are in the many, many millions 6 of dollars. And that is going to be the bigger problems in 7 terms of an incentive to come forward.
8 COMMISSIONER BERNTHAL: But the -- let me see 11 I 9 understand right here. My thinking and my presumption was 10 that the three vendors already have a design that is close to 11 something that they could consider coming in for design j 12 certification approval on at this point.
13 Is that true?
14 And that that is a $10 million, roughly, proposition
- 15 or something like that?
16 MR. MIRAGLIA: I think that is a separate question, 17 the fee question, isn't it?
18 MR. THOMAS: Yes.
19 MR. MIRAGLIA: For going forward with the design 20 certification.
21 MR. THOMAS: It can be related. I don't think we i
22 have addressed the fees associated with the certification 23 process. Only through the design approval proqess right now.
24 MR. STELLO: They already have it.
l l 25 COMMISSIONER BERNTHAL: I see. Only the final l
l l
, , , . , - -- r. .s-- - - - ,e -w
. ; 39 1 design approval process. And you haven't considered applying 3 that to design certification?
l+
3 MR. MIRAGLIA: We l'1, I,think it one looks at the fee 4 structure, there is a c'a p on.the tee. And dependent upon 5 whether you start the fee structure all over for the design 6 certification. I don't know it that is clear.
7 MM. THOMAS: We do intend for the proposal here to 8 apply to the certification process. It is just that no fees 9 have been established for the certification process.
10 COMMISSIONER BERNTHAL: Well then I will got 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 3 MR. THOMAS: Well, 11 you assume thei, 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, halt 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 24 magnitude, in addition.
25 COMMISSIONER BERNTHAL: That sounds low to me.
l
. 40 1 I had been using in my own mind the number slo 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: The legal fees would begin to 6 approach that $$00,000 a year.
7 Excuse me.
8 MR. MIRAGLIA: Also, the propostd policy indicates 9 that final design approvals, design certifications 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 12 the final design process.
13 And so that element has been incorporated into that.
14 CHAIRMAN PALLADINO: Could you refresh my memory.
15 Why do we have PDAs? What are we approving? Is it a l 16 preliminary approval of a design, or is approval of a 17 preliminary design?
18 MR. MIRAGLIA: It would be a design approval that 19 would allow, perhaps, construction to go forward.
, 20 CHAIRMAN PALLADINO: Answer my question. Is it 21 approval of a preliminary design, or-is it preliminary approval 22 of a --
23 MR. MIRAGLIA: It would be consistent with the level 24 of design inicrmation necessary to issue a CPU, PSAR type 25 information.
- 41 1 MR. STELLO: The concept is, 11 someone were to 2 submit a CF 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 "^w 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, j 12 submitted as a separate package, and then you would not need 13 to 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 CHA12 MAN PALLADINO: So far as the individual 21 performance is concerned?
22 MR. STELLO: 'That*s correct. That's the reason and I
23 the concept. _
l l 24 COMMISSIONER ASSELSTINE: There is nothing wrong 25 with the FDA concept.
l
. 42 1 I guess where I have difficulty though is saying j 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 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.
l 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.
l 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 25 plant.
.. 43 1 That was what I thought we were talking about here.
2 I thought PDA and FDA were sort of steps along the way that 3 have no direct applicability to what the Commission's view of 4 standardization really is.
5 Am I off on a tangent?
6 COMMISSIONER ASSELSTINE: I think that is fair.
7 MR. THOMAS: In the past, the PDA and FDA were 8 analogous to a CP 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 re+erence design. But, it is now the
( 19 reference design thwt becomes the trigger for the ability to j 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 don't think they 23 are a necessary part of the standardization process.
l 24 MR. MIRAGLIA: The policy statement doesn*t have 25 that kind of language. But t i.a t is certainly something that
l
- 44 1 can be considered.
3 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 stuit into the pot.
9 COMMISSIONER BERNTHAL: I agree. I think it doesn*t 10 matter so much what we call the standardized plant concept.
11 What matters, really, is how we go about doin2 this.
12 And driving the process to achieving a design 13 certification -- and I wilr 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.
l L
23 MR. MIRAGLIA: May I have the next slide, please?
, 24 [ Slide.3
! 25 MR. MIRAGLIA: As Mr. Stello had indicated in l
, 45 1 discussions with the industry, it was clear that some period i
2 of transition would be necessary in implementing the l 1
1 3 standardization policy, and the industry view that was l 4
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 12 there should be any relief from those based on good cause 13 shown and good evaluations indicating the degree that those 14 conditions should be complied with.
s 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 requirements, and that was July '82 or '83, 19 I believe. That plant design could be replicated at any
! 20 site. 11 it was not reviewed to that version of the SRP, it 21 could be replicated at the same site by the same operator, and t
22 in addition would have to be supported by the design l 23 performance and operating history of that faci ity as a 24 consideration of a plant for replication.
2$ It it was a plant that has run well and the design
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I
= I 46 1
1 ts snown to be proven and has a good operating history, we 2 would consider replication of that same design, operated by i
3 the same designer at the same site, as a point of departure l l
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 SEP, 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 with what 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, i
21 anyway, we are willing to buy replication, let*s say, of a 20 SNUPPS plant. But beyond then, we expect something different 23 and better.
l 24 COMMISSIONER ASSELSTINE: This non NUREG 0800, l
j 25 though, would be broader than-that? That could be an older t
j j
47 1 plant?
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 statemant recognizes that that is the 8 Commission's desire to achieve this true certification 9 process. But what it fails to do is identity 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 14 judgment. We otter no judgment except to say that*s the 15 direction that the Commission wants to go.
16 COMMISSIONER 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 --
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 1 don't know how to do that. All we say is, its 25 intent is to move in that direction, but I don't know, i
l
, _ r .- , . - - ~ - - - , , - - , + -
O a 46 1 Let me see if I can give a simpler answer. NUREG 2 0800, that's in a sense a benchmark in time. Here were all j I
3 the requirements laid out comprehensively in NOREG 0800 in, I I 4 think it was, '83 and then it says from then on, these are a 5 different class of plants from those that were before then.
6 'The ones before, if you want to build one at the same site, 7 same operator, we don't 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 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 4
18 constructed in the policy standard --
replication concept 19 would still be an att a i l a b l e concept. It is not a sunset 20 provision for that as currently written. I got the sense that i
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.
i 24 CHAIRMAN PALLADINO: I'm confused. hour answer was 25 yes, it is a sunset provision.
. 49 1 MR. STELLO: Only in terms of the Commission's 2 desire, but not in terms of an actus1 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 t
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 19 determine how soon you say no more replication, because we l 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 ,
l 23 those any more. There are better things now. ,
l 24 CHAIRMAN PALLADINO: I'm a little confused.
25 COMMISSIONER BERNTHAL: That's a rolling judgment i
1 l
l 2
$0 1 we'll have to make.
2 CHAIRMAN PALLADINO: I raised the question because I 3 was worried that we were setting a timeirame to limit ;
l 4 replication.
5 MR. STELLO: No.
6 CHAIRMAN PALLADINO: That*s why I raised my 7 question. When you say, well, we're going to allow replication 8 for five years after the policy statement --
which is fine as a 9 target, and I wanted to make sure that we had a way out, if 10 events-shesed the situation to be different from the way we 11 perceive it now. And now you are saying, well, you don't want 12 to put the five years, 11 I understand you, so tell me what it 1 13 is again that you are telling me.
14 MR. MIRAGLIA: For a plant that's licensed -- it we 15 had --
let's assume five years when the policy statement is 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.
22 CHAIRMAN PALLADINO: Then what does,the five year --
23 MR. MIRAGLIA: This extension here of- saying five I
l 24 years from the policy statement is recognition that there have f
25 been a number of plants recently licensed that we would be i
i ___ .. . . - . . - . . - - . . - - -
~
. s 51 1 saying their term of referenceability that would be 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 7 years?
8 CHAIRMAN PALLADINO: That is the way it svunds.
9 COMMISSIONER BERNTHAL: That*s very lid. esting.
10 I'm not sure --
11 CHAIRMAN PALLADINO: That's why I was confused. I 12 wish you would clarify 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 build 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
. 52 1 preclude a utility from having its own design certified.
2 COMMISSIONER ASSELSTINE: They are not going to oc 3 that as a practical matter, 4 MM. 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
? intermediate term there, and for replication we have allowed a 8 plant to be replicated, not automatically but a proposed 9 application that would replicate a previous plant would have le to underga a qualification review. The Staff 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 atJ t o m a t i c -- 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 --
l 22 P.R . MIRAGLIA: It was ovr desire to,replit.te within 23 tha' timeirame, but it would be a conscious decision, "Yes, 24 this plant should be replicated."
25 COMMISSIONER BERNTHAL: But as the Chairman says,
.-- - - - ~ ,
$3 I 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 fell last year?
4 MR. MIRAGLIA: I think you could make that kind of
$ decision again on a case-by-case basis.
6 COMMISSIONER ASSELSTINE: When dID the NUREG 0800 7 plants start? After St. Lucie?
8 MR. MIRAGLIA: Well --
9 COMMISSIONER ASSELSTINE: Or do they vary 7 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 *B3, 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 esrly 23 1990s, perhaps. But I have just got ts believe by the
~
i i 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
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 7 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 replicate these plants. So I get 10 confused by introducing those terms, especially when I can
- i 11 replicate at the same site at vehich I can duplicate. It 12 depends on the timing, and I suggest you give a little more 13 thought 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 att 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 --
25 CHAIRMAN PALLADINO: When I get a standard design, I
1 have to replicate them --
2 MR. STELLO: That*s a certified design, anc you do 3 those. That*s different.
4 CHAIRMAN PALLADINO: That*s not replicate.
$ MR. STELLO: No.
S CHAIRMAN PALLADINO: I can*t use the word I'm going 7 to replicate standard design?
8 MR. STELLO: No, because the Commission's policy 9 statement differentiates 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 16 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. Hcw long 19 will that take? I don *t know. But 11 you look at any of the
. 20 advanced reactor concept, it is very unlikely that you would 21 ever even have one in operation, built in the next 15 years.
22 COMMISSIONER BERNTHAL: The point 1s replication and 23 duplication have literally nothing to do with standardization 24 as the Commission envisions it. I think that is why it is a 26 distraction, almost, to be so concerne;i right now about that
56 I transition possibility.
2 MR. MIRAGLIA: It's a standardization in a dikterent i
3 and more limited sense than having --
4 CHAIRMAN PALLADINO: Maybe the actuality that we are 5 going to face --
6 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 l
l 8 industry has suggested they want in terms of a market, what 9 they are going to buy.
10 Now it 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, it there is anybody that knows what the market is, 13 except the best advice I think you can get in terms of what 4
14 the market would be are the people who will buy them.
15 If 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," it this is what they tell you
- 18 they war.
- It clearly -- the Commission has the authority to 19 say no.
l 20 COMMISSIONER BERNTHAL: We are not suggesting that.
i l
l 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 i
23 duplication and replication, to be sure, are an essential 24 practical feature of whatever policy we come up with, but it l 25 is not saying that we want our Sizewell II, if you will, in l
, 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 stuff 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, i' .
? seems to me.
8 COMMISSIONER ASSEi,STINE: It does seem to me that 9 what we ought to do is maybe have a little better fix on how 10 this all fits 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 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 tikely is it that utilities will be ordering additional plants 1
23 between now and the early 1990s, and what their interest it.
~
l l
24 I would almost like to see a survey of utility CEOs, write l
, 25 them and ask them, "Do you envision ordering another nuclear i
, 50 1 power plant between now and the early 1990s? And 11 so, what 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 1
12 the plants that have been deferred.
13 Maybe I am wrong about that, but I haven *t heard a z
14 lot of utility executives that say, "Yes, I want to build i
15 another p1 ant" --
16 MR. STELLO: One way I think you can 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 I
i 19 consider, since we have an industry group called NUMARC, i
l 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 drait or suggest a modifications 23 policy -- but the simple question, "Does this policy statement l 24 allow the kinds of options that you foresee necessary, in your r
j 25 view, what you would do if you were to in fact order another i
l l
O
$9 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 Jam 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 1
13 say, "You know, we think it is really realistic that somebody 14 could come in and they'll order another SNUPPS plant or order 15 another GESSAR plant or System 80 plant. We think that's 16 really realistic."
17 You 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 Ilght 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.
I
60 1 COMMISSIONER ASSELSTINE: The problem with AIF is 2 AIF represents the full spectrum of the industry, and what ycu 3 may be seeing is the vendor perceptions, who aren't the people 4 who are going to be buying them.
5 COMMISSIONER BERNTHAL: We do have a request irom 6 AIF to come in and speak to us --
7 CHAIRMAN PALLADINO: I*11 bring that up at the 8 agenda-planning. We had a conversation on that.
4 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 i
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 briet 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 Statt 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
. 61 1 be 10 years.
s%
2 Again, the reason for the Staff 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 l 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 it there is good cause, 11 we are heading 12 towards 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 Staff's thinking 20 is along the lines we need information equivalent to final 21 design FSAN information. The dialogue with AIF, the indication 22 is something in between, maybe, or less than that might be 23 acceptable.
24 I think AIF recognizes there is a need for both l 25 industry and the Staff to really come to grips with what
62 1 exactly the level of design information is needed to fulfill
.s 2 the terms of .equirements.
3 CHAIRMAN PALLADINO: This is a t unt' amen t a l question, 4 and I can't understand why they want less than the FSAM for 5 final design approval, or design certificatton.
6 As a matter of fact, in my own thinking, I would 7 expect more than the 13AH.
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 l'4 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 i 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
~
I J .
23 be tinkered with later on, or throughout the process.
~
i 24 MR. STELLO: Frank, I think I recall one other 25 consideration that stands out. One of the other concerns they
63 1 had was when you put in an FSAR, you can say you bought a
% l 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 i
4 incorporate that level of detail, they're concerned about S 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 it exists, it's here, and you i
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 do 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.
22 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 I
i
. 44 1 what you embody in the regulations for design certification, 3,
2 then that causes us to have a problem with antitrust, as I 3 understand it.
4 CHAIRMAN PALLADINO: It we start to do it?
5 MR. STELLO: No, when we get to design certification 6 and pt'tting 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 11 you have FSAR and we approve it, we 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 be a way around the problem.
21 We also ought to look at this; to the extent you can specify 22 performance characteristics, it doesn't necessarily tie you to 23 a specific manufacturer or a specific nameplate component, as 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
l
1 65 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 o' 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 COMMISSIONER 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 mare deeply you get into that, the more deeply we 11 kre going to get as an agency into vendor certification. Tom 12 isn't here. And that would be the vendor _ inspection.
I '3 COMMISSIONER ASSELSTINE: The Aame 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 identify 16 the level of information you need to resolve all the safety i
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.
2e MR. MIRAGLIA: All we are trying to identity here is !
i 1
l 25 that this is an issue, and we use the word " equivalent." They i
\.,,,.-, - - . ~ - , - - - - . . . r - _ . , ,.-m _ ,y_g. c , . - ,-
60 1 are saying "less than." Maybe we should --
it's a semantic 2 kind of thing, and there is certainly room for more dialogue.
3 COMMISSIONER ASSELSTINE: It might be useful to talk 4 to FAA to see how they avoid that very ditticulty, because 4
5 they certify designs and those designs are, I think, very 6 complete when they do the certification.
7 COMMISSIONER BERNTHAL: Do they certify vendors or 8 do they --
9 COMMISSIONER ASSELSTINE: I think they get into 10 that, too.
11 CHAIRMAN PALLADINO: Why not find out what is done 12 in the aviation industry?
i 13 As long as you are on this FDA, can I ask a question 14 I was confused on? In the document that says, "However, an 15 approved final design is subject to litigation," this is under 16 final design approval. And individual licensing proceedings 17 on these applications. Do you mean if you have an FDA, you 18 still have to litigate the whole matter, or do you just 19 litigate those things that relate to the site and that interact 20 at the site?
21 MR. MIRAGLIA: The final design approval that is 22 being described there is the design, prior to going to the l
23 design certification and hearing. Therefore, 11 you haven *t 34 completed that 4tage, then those issues are ripe for 25 consideration in the individual application.
- 67 1 CHAIRMAN PALLADINO: But,this says you have to j 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 rulemaking, 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 --
8 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 f o r e c 1'o s e '
13 everything except the site-specific offsite issue.
14 COMMISSIONER ZECH: Ohich is what we intend to do.
15 y 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 e .
19 design is not subject to litigation in individual licensing i
20 proceedings. And these are applications. That is on the
'N 21 basis that it goes to rulems%2n 22 Then when it cfres ,e final design approval, it says 1
23 litigation -- an approved final design is sub)Ect to litigation 24 and individual licensing proceedings. That's because we 25 haven't gone rulemaking? ,
I 4
4 i
\
66 1 COMMISSIONER ASSELSTINE: That's right. Design 2 approval is just the Statt sign-off, the Staff is satisfied, 3 without the Commission process for approving, certifying it. l 4 CHAIRMAN PALLADINO: Okay. Sorry to interrupt. Why 5 don't we continue, give you a chance to continue.
6 MR. MIRAGLIA: 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 backfit rule. The 9 industry considered that application should be based on the 10 backiit on the lead plant, the difference being, as we 11 perceive, using the backiit rule on the plant that we are 12 considering.
13 CHAIRMAN PALLADINO: I think we have a real problem 14 it we start to do extensive backfitting on the plants that are 15 being replicated or duplicated.
16 MR. MIRAGLIA: What the concepts say is we would 17 follow Commission's policy with regard to this.
19 MR. STELLO: The issue, I think, is a simple one.
19 If you are going to.backfit, 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 22 considerations in deciding whether or not to backfit would be 23 completely different than 11 it were a new plan't being 24 -designed. And the backiit rule recognizes those differences 25 and tells you what to do. And all we said is that we are
69 1 following the rule. Their proposal would be a departure from 2 the rule.
3 COMMISSION 8R ASSELSTINE: Yes. That's right.
4 Because considerations could be very, very different. You
$ could have 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. 11 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 if you do change, you are required 17 to follow the Commission's backfit rule. In following that 18 rule, there are two ways to do it. We want to follow it 19 literally as it's spelled out in the backfit rule, and they l
1 20 are suggesting something different. I 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.
1 25 CHAIRMAN PALLADINo- I very much. appreciate receiving i
l 70 i i
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 4
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 t a l k i ,n g about here, I i
23 don *t think anyone, not even Fred Bernthal in some speeches t .
1 24 he's made, suggesting you might see construction by 1990 or
( I l
25 shortly thereafter, has suggested that within five years from l
f l
- - _- _ _ . ~ . _ _ . , . . _ . - , , , , . . , , . _ , . , ,_ _ _ , . _ , . . . . . . . _ __ _ . , . . . _._
71 l
1 now we will see new plant applications. And then the question 2 becomes in 1989 or 1990, actually Staff is saying five years 3 from '83, I guess -- 1988, if you wi$1 -- 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 techno1cgy 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.
19 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 t i m ,e . That does not 23 mean that after a period of time you shouldn*t say we want a 24 different fix, but it dces mean for a period of time you fix 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 whether 3 you were in one, two, three or tour.
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 ditterent set of circumstances.
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 11 points in time in which we would encourage new ones. Just like 12 we got the DC-3. Some of them are still running, but that 13 doesn*t mean --
14 COMMISSIONER BERNTHAL: We don't build them any 15 more.
16 COMMISSIONER ASSELSTINE: But you don't build a new 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.
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
. ,e ,
. 73 1 that is something we can.ask the utilities. It is not clear 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, if I may, 11 couple of comments.
12 First of all, this Commission and the Statt 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 tc me timing is really part of what we are l
l 35 talking about and it's a big, big thing to be considering, and
. . ._ _ . _ . .~._ _ . . . . -. .
74 -
1 so we can't Just. I don *t think -- even though it might be 3
- 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 i
5 why I have used the teru generations before. I think about it i
6 this way, anyway. I think we ought to have two generations of 3
- -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.
1
{
12 Also in the first generation we might include a 4
13 third category. That would be perhaps under duplication, f
! 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 i
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.
I 23L The second generation I look at in two categories; I .-
24 One,-the advanced reactor. We don't know what that 25 is going to be, but hopefully that is being worked on.
{
r 75 1 And also, the second category then of the second i
2 generation would be perhaps even a more evolutionary change j l
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 teasible, rather than just be concerned with 6 all the difficulties it looks like in getting from here to 7 there. So I think that's a good way to think about it 8 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 ottices' assistants work with OPE and with 12 the Staff 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 17 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 i
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 E
23 want.
24 But again, my thinking is this is first generation, 25 second generation, so it is feasible. As we mentioned earlier, i
l
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 NUEEG that would perhaps discuss the issues 15 and topics in execution, some of which we have talked about 16 here today, too. It seems to me that is the approach we ought 17 to take.
18 So I think the Statt has done a good job, but it is l 19 a very important issue, and we should not let it drag on l
I 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. '
I 23 I think that the Commissioners have a responsibility _
24 now. The Statt has done a fine job, and now it is up to us, !
25 think, to take a more active role. I suggest that's what we
.o
??
I 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 it 6 we go for outside opinions, I'm not sure how quickly we are 7 going to be able to get them. But it we can go out for the 8 outside opinions while our staffs are working with OPE and the 9 Stait, then we might be able to save a little bit of time.
4 10 I'd like to see us get the standardization policy out the 11 first half of 1986.
i 12 COMMISSIONER ZECH: I*m al1 ior gotting it out soon,
' ~
13 but it*s so important, 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 l
18 from industry and those groups we have mentioned is important l
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 CHAIMMAN PALLADINO: This would be g
,oing out for 23 comment, anyhow.
24 COMMISSIONER ZECH: That*s why it is so important we 25 have it coordinated the best we can.
T l
l 78 l
1 CHAIRMAN PALLADINO: As I understand it, you propose 2 that we get our assistants working together with OPE 3 participating?
4 COMMISSIONER 2ECH: The Stati should be involved. I 5 suggest they get somebody full time from the Statt to 6 participate in this group, if 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 Statt has done that.
12 CHAIRMAN PALLADINO: No , generally we react. One 13 way to react is to get OPE and the statis, 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 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 Sisewell II ready for the 1990s. It 25 may well be that a utility, one or more utilities comes in in
79 1 the intervening years -- by 1990, perhaps -- and says, "We 2 would 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 overy major vendor, assuming they are willing to step forward a
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 after here is a design certification of a 12 Sizewell type at a Sizewell type level 13 If I ask myself, are we going to 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 i 20 how to proceed.
I 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 1 -
24 particular scheme, because we want to make sure this Ccamission 1
25 input is provided and the suggestion that the assistants get
4 j
80 1 together with OPE to develop a consensus position, I think that
-s' 2 is a good approach. ,
3 Then what do us 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 find any fault with what 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 Statt has done a fine job. They I 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 18 Commissioner 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 Stati, a n,d I don *t have 23 any problem with providing our input. I guess _I view things 24 as Fred has }ust described them. I think that is more of a 25 restructuring of what is here than simply line-tuning or
8&
1 editing, and I think somebody is going to have to put some s
2 effort in 11 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. It somebody wants to come 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 teature of our standardisation policy, I think is a mistake.
10 I agree with Fred on that. It seems to me what we ought to 11 say is standardisation 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 ci it and use it and take out some of 15 this other stuti and look at those things on a case-by-case 16 basis. It anybody really is interested in pursuing them.
17 I would like to see, you know, some ottort made to 18 reformulate the policy statement along those lines; whether 19 it's OPE or the Statt doesn*t matter to me.
20 CHAIRMAN PALLADINO: What we are trying to do is 21 provide a veh! ole 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 ditter a little bit in the tact that I believe 25 we should at least recognise that duplication and replication
O 02 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 emphasise our goal of 4 getting to a certification, a standardisation 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 6 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 buildt ;
! 10 plants in our country. I think that would probably be an 13 irresponsible regulatory action on our part.
l 14 COMMISSIONER BERNTHAL: I don *t think anyone is 1
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 Stati and whatnot.
19 COMMISSIONER ASSELSTINE: Yes.
20 COMMISSIONER BERNTHAL: It's a question of emphasis, 21 I agree.
22 CHAIRMAN PALLADINO: Let me make t h,e suggestion, 23 picking up your point, that we each give our respective views i
24 to our assistantJ, and then the assistants, working with the 25 OPE, meet to reach a consensus on what ought to be done with t
83 1 regard to this.
2 COMMISSIONER ASSELSTINE: Sure.
3 COMMISSIONER ZECH: Very good.
4 CHAIRMAN PALLADINO: Then in parallel I would also 5 ask the Statt to discuss with NUMARC, or perhaps some other 6 group, if it seems more appropriate, to get background i
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.
10 COMMISSIONER 2ECH: Okay.
11 CHAIRMAN PALLADINO: Thank you very much, gentlemen.
12 That was a very interesting discussion.
13 Okay, we will stand adjourned.
14 CWhereupon, at 12:05 p.m., the meeting was 15 adjourned.3 16 17
! 18 19 20 s
21 i
22 e
23 24 25 l
l t
t 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: COMMISSIO!I MEETING e
9 Name of Proceeding: Briefing on Policy Statement on Nuclear Power Plant Standardization (Public Meeting 10 11 Docket No.
i 12 PIace: Washincton, D. C.
13 Date: Wednet. day, December 11, 1985 14 15 were held as herein appears and that this is the original 16 transcript thereof for the file of the United States Nuclear 17 Regulatory Commission.
'S ' '
l . . , ' _i (Signature) (,7 [ 67 fy f
(Typed Name of Reporter) Mimie Melt;$pr' 20 21 ,
'22 23 Ann Riley & Associates, Ltd.
24 l
l l 25
12/11/85 PROPOSED REVISION TO STANDARDIZATION POLICY STATEMENT -- BRIEFING OUTLINE i
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 a
1 FMIRAGLIA/NRR x27980 .
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s 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-l ZATION, AND REQUESTING COMMENTS AND SUGGESTIONS l ON CHANGES ISSUED
! AUGUST 1978 MOST RECENT POLICY STATEMENT ISSUED FMIRAGLIA/NRR -
- x27980 _
I T
E
l l
i NEED FOR REVISING 1978 STANDARDIZATION POLICY STATEMENT STAFF'S EXPERIENCE IN IMPLEMENTING STANDARDIZATION PROGRAM PROVISIONS OF SEVERE ACCIDENT POLICY STATEMENT PROVISIONS OF DRAFT NUCLEAR POWER PLANT LICENSING AND STANDARDIZATION ACT STAFF'S CURRENT VIEWS ON STANDARDIZATION FMIRAGLIA/NRR .
x27980
4 i
i 1
RETAINED PRESENT STANDARDIZATION CONCEPTS !
i I
i REFERENCE SYSTEM DUPLICATE PLANT i
REPLICATE PLANT 5
- . MANUFACTURING l! CENSE i i
I FMIRAGLIA/NRR .
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x27980 I
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e SIGNIFICANT PROPOSED REVISIONS TO 1978 STANDARDIZATION POLICY STATEMENT 2
SEVERE ACCIDENT POLICY STATEMENT LICENSING REQUIREMENTS 2
DESIGN CERTIFICATION OPTION STAFF / COMMISSION CHANGES TO APPROVED DESIGNS MORE RESTRICT! vet INDUSTRY CHANGES LESS RESTRICTIVE DUPLICATE-PEPLICATE PLANT REFERENCEABILITY PERIOD OVERLAP ELIMINATED l
REFERENCE DESIGN FEES ALLOCATED AMONG USERS FDAS AND DCS REFEWABLE PDAS RENEWABLE FOR GOOD CAUSE FMIRAGL I A /NRR _
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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 _
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- DIFFERENCES BETWEEN STAFF- AND AIF-PROPOSED STANDARDIZATION POLICIES -
ISSUE STAFF AIF TERMS OF APPROVAL DC - 10 YEARS; ALL CONCEPTS -
OTHERS 5 YEARS 10 YEARS PDA RENEWABILITY FOR GOOD CAUSE YES 1
LEVEL OF DESIGN DETAIL EQUIVALENT TO LESS THAN FOR FDAS AND DCS FSAR FSAR COST-BENEFIT ANALYSIS BASED ON BACKFIT BASED ON LEAD FOR COMMISSION / STAFF RULE UNIT CHANGES FMIRAGLIA/NRR x27980 i