ML20155G939
ML20155G939 | |
Person / Time | |
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Issue date: | 05/01/1986 |
From: | Office of Nuclear Reactor Regulation |
To: | |
References | |
REF-10CFR9.7 NUDOCS 8605090028 | |
Download: ML20155G939 (33) | |
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UNITED STATES OF AMERICA ;
! NUCLEAR REGULATORY COMMISSION l 1
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In the matter of: i 1 l COMMISSION MEETING l Affirmation / Discussion and Vote i (Public Meeting) _y Docket No.
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{ Date: Thursday, May 1, 1986 Pages:
i e60euvoo28 860501 PDR 10CFR PDR PT9.7 i
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.I 1 , ANN RILEY & ASSOCIATES
! Court Reporters
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6 This is an unofficial transcript of a meeting of the
? United States buct' ear Regu l a tory Corwni ss ion he ld on a 5/01/86 . in the Commission's offica at 1717 H Street, 9 N.W.. Washington, D.C. The meeting was open to pubiic ,,
10 attendance and observation. This transcript has not beern 11 reviewed, corrected, or edited, and it may contain 12 inaccuracies.
1S The transceipt is intended sole 1y for genera 1 14 informational purposes. As provided by 10 CFR 9.10S, it is 15 not part of'the formal or informal record of decision of the 16 matters biscussed. Expressions of opinion in this transcript 17 do net necessarily reflect final determination or beliefs. No 18 plearfing or other paper may be filed with t he . Ccern i s s i on in 19 any proceeding as the, result of or addressed to any statement 20 or argument contained herein, except as the Commission may 21 authoriza, 22 2T!
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1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3
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6 Public Session 7 ------
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AFFIRMATION / DISCUSSION AND VOTE 10 r
11 1717 H Street, N.W. ,
- 12 Room 1130 -
! 13 Washington, D.C.
14 Thursday, May 1, 1986 15 16 The Commission met in public session, pursuant to !
17 notice, at 11:55 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 Frederick M. Bernthal, Member of the Commission 22 Thomas M. Roberts, Member of the Commission 23 Lando W. Zech, Jr., Member of the Commission 24 STAFF SEATED AT COMMISSION TABLE:
25 S. Chilk, SECY I
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PROCEEDINGS 2 CHAIRMAN PALLADINO: Would you please come to order.
3 This is an affirmation session, and I will ask the 4 Secretary to lead us through the item we have on the agenda.
5 MR. CHILK: The paper, Mr. Chairman, is SECY 85-279, 6 a revised Advanced Reactor Policy Statement.
7 The Commission is being asked in this paper to 8 approve the issuance of an Advanced Reactor Policy Statement.
9 The primary objectives of the policy statement are to 10 encourage early as possible interaction with the applicants, r
11 vendors, and government agencies with the NRC to provide all 12 interested parties, including the public, with the 13 Commission's views concerning the desired characteristics of 14 the advanced reactor designs, and to express the Commission's 15 intent to issue timely comment on the implication of such 16 designs for safety and regulatory process.
17 The Chairman, Commissioners Roberts, Bernthal and 18 Zech agree. I have attached the approved policy statement 19 which is attached to our Memorandum of April'30th.
20 Commissioner Roberts, while approving, is deeply 21 concerned about the statement -- page 6 of the statement, 22 specifically, whereby the Commission commits advanced reactor 23 designs to comply with a forthcoming safety goals policy 24 statement before the safety goals policy statement is 25 finalized, and while the final wording is still fluid.
0 3
1 Commissioner Asselstine, although unable to attend 2 this affirmation, has disapproved the policy statement. His 3 separate views are attached.
4 Would you please affirm your votes.
5 CHAIRMAN PALLADINO: Aye.
6 COMMISSIONER ROBERTS: Aye.
7 COMMISSIONER ZECH: Aye.
8 CHAIRMAN PALLADINO: Did you vote?
9 COMMISSIONER BERNTHAL: Well, actually, I had a 10 minor editorial change I was going to suggest. We ought to ,
11 give the opportunity to do those things. It's purely for .
12 consistency. There was a lot of discussion about 13 " anticipates" versus " expects" throughout this document, and 14 there is one instance where correction of consistency was not 15 made, and that is on page 2, I think, in the summary, whereas 16 everywhere else we are now saying and agreed to say the 17 Commission expects an advanced reactor will provide more 18 margin prior to exceeding safety limits, et cetera, et 19 cetera. There is an " anticipates" that remained in the 30 summary in the introduction there, so we are now using both 21 words, and I think we probably ought to be consistent with 22 what we agreed later on in the document.
23 If that is too big a change, then I guess it doesn't 24 matter that much.
25 MR. CHILK: Why don't I make the change and walk it i
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1 'around --
2 COMMISSIONER BERNTHAL: Yes, I think we ought to try 3 and be consistent on that.
4 CHAIRMAN PALLADINO: All right, so our approval is 5 subject to --
6 MR. CHILK: Subject to this one-word change.
7 CHAIRMAN PALLADINO: -- this one-word change, if 8 possible. Okay. All right.
9 Now are you ready to vote?
10 MR. CHILK: Will you all affirm your votes on that, !
11 please? ,
12 CHAIRMAN PALLADINO: Aye.
13 COMMISSIONER BERNTHAL: Aye.
14 COMMISSIONER ROBERTS: Aye.
15 COMMISSIONER ZECH: Aye.
16 CHAIRMAN PALLADINO: Anything more to come before 17 us?
18 MR. CHILK: No, Mr. Chairman.
19 CHAIRMAN PALLADINO: All right. Thank you very 20 much. We will adjourn the affirmation.
21 [Whereupon, at 11:58 a.m., the affirmation was 22 concluded.]
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2 REPORTER'S CERTIFICATE 3
4 This is to certify that the attached events of a 5 meeting of the U.S. Nuclear Regulatory Commission entitled: ,
i 6
7 TITLE OF MEETING: Affirmation / Discussion and Vote (Public Meeting) '
8 PLACE OF MEETING: Washington, D.C.
9 DATE OF MEETING: Thursday, May 1, 1986 10 11 were held as herein appears, and that this is the original ,
12 transcript thereof for the file of the Commission taken 13 stenographically by me, thereafter reduced to typewriting by 14 me or under the direction of the court reporting company, and 15 that the transcript is a true and accurate record of the 16 foregoing events.
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i NUCLEAR REGULATORY COMMISSION 10 CFR PART 50 POLICY FOP PEGULATION OF ADVANCED NUCLEAR POWEP PLANTS AGENCY: NUCLEAR REGult.TOPY. COMMISSION ACTICN: FINAL PCLICY STATEMENT
SUMMARY
- THE COMMISSInN INTENDS TO IMPROVE THE LICENSING EFVlo0NMENT F0P ADVANCED NUCLEAR POWEP REACTORS TO MINIMIZE COMPLEXITY AND UNCERTAINTY IN THE REGULATORY PPOCESS. IHIS STATEMENT GIVES THE CCMMISSION'S POLICY REGARDING THE REVIEW OF, AND DESIRED CHARACTERISTICS ASSOCIATED WITH, ADVANCED REACTORS.
THIS POLICY STATEMENT IS A REVISION OF THE " PROPOSED POLICY FOR REGULATION OF ADVANCED NUCLEAR POWER PLANTS" THAT WAS PUBLISHED FOP COMMENT ON MARCH 26, 1985 (50 FR 11884).
THE COMMISSION'S PRIMARY OBJECTIVES IN ISSUING AN ADVANCED REACTOR POLICY STATEMENT ARE THREEFOLD:
FIRST, TO ENCOURAGE THE EARLIEST POSSIBLE INTERACTION OF APPLICANT, VENDORS, AND GOVERNMENT AGENCIES, WITH THE NRC; SECOND, TO PROVIDE ALL INTERESTED PARTIES, INCLUDING THE PUBLIC, WITH THE COMMISSION'S VIEWS-CONCERNING THE DESIRED CHAPACTERISTICS OF ADVANCED REACTOR DESIGNS; AND
THIRD, TO EXPRESS THE COMMISSION'S INTENT TO ISSUE TIMELY COMMENT ON THE IMPLICATIONS OF SUCH DESIGtlS.FOR SAFFTY AND THE REGULATORY PPCCESS.
4 SUCH INTERACTION AND GUIDANCE EAPLY IN THE DESIGN PROCESS SHOULD EtHANCE STABILITY AND PPEDICTABILITY IN THE LICENSING AND REGULATION OF ADVANCED REACTOPS.
ADVANCED PEACTORS ARE CONSIDERED HERE TO BE THOSE REACTORS THAT APE SIGNIFICANTLY DIFFERENT FROM CURRENT GENERATION LIGHT WATER REACTORS UNDEP CONSTRUCTION OR IN OPEPATI0t!. THE COMMISSION EXPECTS THAT THESE DESIGNS WILL PEFLECT THE BENEFITS OF SIGNIFICANT RESEARCH AtlD DEVELOPMErlT WORK, AND INCLUDE THE EXPEPIENCE GAINED IN OPERATING THE MAtiY POWER AND DEVELOPMEt:T REACTORS BOTH IN THE UNITED STATES-AND THROUGFOUT THE WORLD.
THE COMMISSION ANTICIPATES THAT ADVANCED PEACTORS WOULD PROVIDE MORE MARGIN PRIOR TO EXCEEDING SAFETY LIMITS AND/0P UTILIZE SIMPLIFIED, INHERENT, PASSIVE, OR OTHEP It!NOVATIVE MEANS TO PELIABLY ACCOMPLISH THEIR SAFETY FUNCTIONS. THE COMMISSION EXPECTS, AS A MINIMUM, AT LEAST THE SAME DEGREE OF. PROTECTION OF THE PUBLIC AND THE ENVIRONMENT THAT IS REQUIRED FOR CURRENT GENERATION LWRS. FOR THE LONGER TERM, THE COMMISSION EXPECTS DESIGNS TO PROVIDE ENHANCED MARGINS OF SAFETY. TO PROVIDE REGULATORY GUIDANCE DURING THE DEVELOPMENT PHASE OF ADVANCED
4 REACTCR DESIGN, THE COMMISSION VISHES TO ENCOUPAGE THE EARLIEST
! POSSIBLE INTEFACTI0t! BETWEEN THE NPC AND OTHER GOVERNMENT AGENCIES, REACTOR DESIGNEPS, At:D POTENTI AL LICENSEFS.
THIS ADVANCED PEACTOP POLICY STATEMENT SETS FORTH THE GENERAL CHARACTEPISTICS OF ADVANCED REACTOR DESIGt!, WHICH THE ~ COMMISSION BELIEVES ADVAf!CED REACTORS SHOULD EXHIBIT, TO INCREASE ASSURANCE OF SAFETY, TO IMPROVE PUBLIC UNDEPSTANDING, AtlD TO PROMOTE MORE EFFECTIVE REGULATION. AS THE AGENCY PESPONSIBLE FOR ASSURING
, THE PROTECTION OF THE PUBLIC FROM THE POTENTIAL HAZARDS OF NUCLEAR POWEP PLANTS, THE COMMISSION WILL KEEP THE PUBLIC INFORMED OF ITS JUDGMENT ON THE SAFETY ASPECTS OF ADVANCED REACTOP DESIGNS AS SUCH DESIGNS COME BEFORE THE COMMISSION.
A REPORT WHICH DISCUSSES THE REVISICMS TO THE POLICY STATEMENT WILL BE PUBLISHED SHORTLY AS NUREG-XXX " TITLE." A COPY OF NUREG-XXX WILL BE AVAILABLE FOR INSPECTION AT THE COMMISSION'S PUBLIC DOCUMENT ROOM,1717 H STPEET, N.W. , WASHitlGTON, D.C.
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REGULATORY POLICY F0P ADVANCED REACTORS THE COMMISSION INTENDS TO IMPROVE THE LICENSING FNVIPONt!ENT FOP ADVANCED NUCLEAR PCWEF REACTORS At:D TO MIFIMIZE COMPLEXITY AND UNCERTAINTY IN THE PEGULATORY PPOCESS. THIS IS A FTATEMENT OF !
THE COMMISSICF'S POLICY FEGARDING THE PEVIEW OF, AND DESf9FD CHARACTEPISTICS ASSCCIATED WITH, ADVANCED PEACTORS. THIS POLICY '
STATEMENT IS A PEVISION OF THE "PPOPOSEP POLICY FOP-REGULATION OF ADVANCED NUCLEAP POWEP PLANTS" THAT WAS PUBLISHED FOP CCMMENT ON MARCH 26, 1985 (50 FR 11884),
i THE COMMISSION'S PRIMARY OBJECTIVES IN ISSUING AN ADVANCED f 4
i REACTOR POLICY STATEMENT ARE THREEFOLD: ,
t i I FIRST, TO ENCOURAGE THE EARLIEST POSSIBLE INTERACTION OF ,
6 APPLICANT, VENDOPS, AND GOVERNMENT AGENCIES, WITH THE NRC; k
SECOND, TO PROVIDE ALL INTERESTED PARTIES, INCLUDING THE [
PUBLIC, WITH THE COMMISSION'S VIEW CONCERNING-THE DESIRED 4
CHARACTERISTICS OF ADVANCED REACTOR DESIGNS; AND THIRD, TO EXPRESS THE COMMISSION'S INTENT TO ISSUE TIMELY '
l COMMENT ON THE IMPLICATIONS OF SUCH DESIGNS FOR SAFETY AND THE REGULATORY PROCESS, L
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SUCH INTERACTION AND GUIDANCE EAPLY IN THE DESIGN PROCESS SHOULD ENHANCE STABILITY AND PREDICTABILITY IN.THE LICENSING AND PEGULATICP OF ADVANCED PEACTORS, THE COMMISSION CONSIDERS THE TEPM " ADVANCED" TO APPLY TO ,
PEACTOPS THAT ARE SIGN!FICANTLY DIFFERENT FROM CURRENT GENEPATION LIGHT WATER PEACTORS (LWRS) NOW UNDEP CONSTRUCTION, OR IN OPERATION AND TO INCLUDE REACTOPS THAT PROVIDE ENHANCED MARGINS OF SAFETY OR UTILIZE SIMPLIFIED INHEPENT OR OTHEP -
INNOVATIVE MEANS TO ACCOMPLISH THFIP SAFETY FUNCTIONS, CURRENTLY, CERTAIN HIGH TEMPERATURE GAS-COOLED REACTORS (HTGRS),
l LIQUID METAL REACTORS (LMRS), AND LIGHT WATER REACTORS (LWRS) 0F INNOVATIVE DESIGN APE CONSIDEPED ADVANCED DESIGNS.
LEGISLATIVF BACKGPOUND THE COMMISSION'S POLICY WITH RESPECT TO REGULATION OF ADVANCED REACTORS IS GUIDED BY THE LEGISLATIVE BACKGPOUND, THE ENEPGY ORGANIZATION ACT OF 1974, WHICH ESTABLISHED THE NUCLEAR REGULATORY COMMISSION, SPECIFICALLY DELEGATED TO NRC " LICENSING AND RELATED REGULATCPY AUTHORITY" FOR DEMONSTRATION NUCLEAR REACTORS OTHER THAN THOSE ALREADY IN EXISTENCE ",,,WHEN OPERATED AS PART OF THE POWER-GENERATION FACILITIES OF AN ELECTRIC
_3 UTILITY SYSTEM, OR WHEN OPERATING IN ANY 0THER MANNER FOR THE PURPOSE OF DEMONSTRATING THE SUITABILITY FCP COMMERCIAL APPLICATI0tl 0F SUCH A PEACTOR. . "THE ENERGY PESEARCH AND DEVELOPf1ENT ADMINISTRATION (fl0W THE DEPARTf1ENT CF ENERGY) WAS CHARGED WITH "... ENCOURAGING AND CONDUCTING PESEARCH AND DEVEL-OPMENT, INCLUDING DEMONSTRATION CF COMMEDCIAL FEASIBILITV AND PPACTICAL APPLICATI0t>S OF THE EXTRACTION, CCNVERSION, STORAGE, TPANSMISSION, AND UTILIZATION PHASES RELATED TO THE DEVELOPMENT AND USE OF ENERGY FR0fl... NUCLEAP... SOURCES."
UNDER SECTION 205 0F THE ENERGY REORGANIZATION ACT, THE NRC MUST PPOVIDE A "LONG-TERM PLAN FOR PROJECTS FOR THE DEVELOPMENT OF NEW OR IMPROVED SAFETY SYSTEMS FOR NUCLEAR POWEP PLANTS." THE NRC IS PRECLUDED FROM DESIGNING, CR DOING RESEARCH ON, COMPLETE NEW DESIGNS FOR THE PURPOSE OF ESTABLISHING OR DEVELCPING THEIR COMMERCIAL POTENTIAL, l PPFVIOUS EXPERIENCE THE COMMISSION HAS HAD EXPERIENCE IN THE REGULATION OF HTGRS AND LMRS AS WELL AS IN THE REGULATION OF LWRS. THE NBC HAS PEVIEWED SEVERAL APPLICATIONS FOR HTGR CONSTRUCTION PEPMITS, AND A CONCEPTUAL DESIGN FOR A GAS-COOLED BREEDER REACTOR, AND 1/ THE GENERAL PRINCIPLE DEFINING THE SCOPE OF NRC'S RESEARCH CAN BE DESCRIBED AS AVOIDING A CONFLICT OF IfiTEREST- "[NRCl SHOULD NEVER BE PLACED IN POSITION TO GENERATE, AND THEN HAVE TO DEFEND, BASIC DESIGN DATA 0F ITS 0WN" AS EXPRESSED IN THE CONFERENCE REPORT TO THE ENERGY REORGANIZATION ACT OF 1974
HAS GRANTED AN OPERATING LICENSE To PEACH BOTTOM-1 AND TO FcPT ST, VRAIM. THE 3'RC ALSO EXPENDED SUBSTANTI AL EFFORT FROM 1975 TO 1979 IN PEVIEUING GFNEPAL ATOMIC'S STANDAPD HIGH-TEMPEFATUPE, GAS-COOLED NUCLEAP PEACTOR STEAM SUPPLY SYSTEM (GASSAR), In ADDITION, THE NRC HAS SUPPORTED A MODEST PP0GPAM 0F SAFETY PESEARCH GN GAS-COOLED FEACTORS EVERY YEAR SINCE THE AGENCY'S INCEPTION, THE COMMISSION HAS ALSO HAD EXPERIENCE IN THE REVIEW AND LICENS-ING OF LMRS. IN THE PAST THE FERMI-1 AND SEFOR REACTORS WERE REVIEWED AND LICENSED, DOE'S FAST FLUX TEST FACILITY (FFTF) WAS REVIEWED AND APPROVED BUT NOT LICENSED, AND A FORMAL CONSTRUCTION PEPMIT LICENSING PROCEEDING WAS CONDUCTED FOR THE-CLINCH RIVER BREEDER REACTOR (CRER), THE CRBR WAS SUBJECT TO THE SAME REGULATORY PROCESS AS ANY CURPENT COMMERCIAL NUCLEAR -
POWER PPOJECT, i
FINALLY, THE COMMISSION NOTES THAT THE PRECEDENT FOR THE BROAD POLICY APPROACH TO ADVANCED REACTOR REGULATION, AS PROPOSED HERE, IS FIRMLY ESTABLISHED IN THE 1979 NONPROLIFERATION ALTERNATIVE SYSTEMS ASSESSMENT PROGRAM-(NASAP), WHEREIN THE NRC ;
CONSIDERED THE SAFETY AND LICENSABILITY OF A VARIETY OF ADVANCED PEACTOP CONCEPTS WITHIN THE CONTEXT OF NONPROLIFERATION l i
CBJECTIVES. THE CONCEPTS CONSIDEPED AND REPOPTED ON BY THE NRC IN THE 1979 STUDY PANGED FROM PPELIf11 NARY C0f'CEPTUAL DESIGNS TO VARIATIONS OF EXISTING (LWP) POWEP PLANTS DESIGNS.
COPMISSION POLICY CONSISTENT WITH !TS LEGISLATIVE MANDATE, THE COMMISSION'S POLICY WITH RESPECT TO PEGULATING t?UCLEAR POWER REACTORS IS TO ASSURE ADEQUATE PROTECTION OF THE PUBLIC HEALTH AND SAFETY AND THE ENVIPONMENT. REGARDING ADVANCED REACTORS, THE COMMISSION EXPECTS, AS A MIfIMUM, AT LEAST THE SAME DEGPEE OF PROTECTION OF THE PUBLIC AND THE ENVIRONMENT THAT IS REQUIPED FOP CURPENT GENERATION LWRS, FURTHEPMCRE, THE COMMISSION EXPECTS THAT ADVANCED PEACTOPS WILL PROVIDE ENHANCED f1ARGINS OF SAFETY AND/CR UTILIZE SIMPLIFIED, INHERENT, PASSIVE, OR GTHER Ifm0VATIVE MEANS TO ACCOMPLISH THEIR SAFETY FUNCTIONS. THE COMMISSION ALSO EXPECTS THAT ADVANCED REACTOR DESIGNS WILL COMPLY WITH THE COMMISSION FORTHCOMING SAFETY GOAL POLICY STATEMENT, AMONG THE ATTRIBUTES WHICH COULD ASSIST IN ESTABLISHING THE ACCEPTABILITY OR LICENSABILITY OF A PROPOSED ADVANCED REACTOR DESIGN, AND WHICH THEREFORE SHOULD BE CONSIDERED IN ADVANCED DESIGNED ARE:
- HIGHLY RELIABLE AND LESS COMPLEX SHUTDCWN AND DECAY PEAT PEMOVAL SYSTEt1S, THE USE OF INHERENT OR PASSIVE MEANS TO ACCOMPLISH THIS OBJECTIVE IS ENCOUPAGED (NEGATIVE TEMPERATURE COEFFICIEtiT, t!ATURAL CIRCULATION),
LCNGER TIME CONSTANTS AND SUFFICIENT INSTRUMENTATION TO ALLOW FOR MCPE DIAGNOSIS AND MANAGEMENT PRIOP TO REACHING SAFETY SYSTEMS CHALLENGE AND/OR EXPOSURE OF VITAL EQUIPMENT TO ADVERSE CONDITIOFS.
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SIMPLIFIED SAFETY SYSTEMS WHICH, WHERE POSSIBLE, REDUCE REQUIRED OPEPATOR ACTIONS, EQUIPMENT SUBJECTED TO SEVERE
- ENVIPCTIMFNTAL C0f;DITIONS, AND COMPONENTS NEEDED FOR MAINTAINING SAFE SHUTDOWN CCNDITIONS. SUCH SIMPLIFIED SYSTEMS SHOULD FACILITATE OPERATOR COMPREHENSION, GELIABLE SYSTEM FUNCTION, AND MORE STRAIGHT-FORWARD ENGINEERING ANALYSIS, DESIGNS THAT MINIMIZE THE POTENTIAL FOR SEVERE ACCIDENTS i 1
} AND THEIR CONSEQUENCES BY PROVIDING SUFFICIENT INHERENT SAFETY, RELIABILITY, REDUNDANCY, DIVERSITY AND-INDEPENDENCE '
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- IN SAFETY SYSTEMS, i i
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DESIGNS THAT PROVIDE RELIABLE EQUIPMENT IN THE BALANCE CF PLANT, (OP SAFETY-SYSTEM INDEPENDENCE FROM CALANCE OF PLANT) TO PFDUCE THE NLMBER OF CHALLFUGES TO SAFETY SYSTEMS, 1
EESIGNS THAT PROVIDE EASILY MAINTAINABLE EQUIPMENT AND COMPONENTS.
DESIGNS THAT REDUCE POTENTIAL PADIATION EXPOSURES TO PLANT PERSONNEL.
DESIGNS THAT INCORPORATE DEFENSE-IN-DEPTH PHILOSOPHY BY i PAINTAINING PULTIPLE BAPRIEPS AGAINST RADIATION RELEASE, AND BY REDUCING THE PCTENTIAL FOR AND CONSEQUENCES OF j SEVEPE ACCIDENTS.
DESIGN FEATURES THAT CAN BE PROVEN BY CITATION OF EXISTING.
TECHNOLOGY OR WHICH CAN BE SATISFACTORILY ESTABLISHED BY :
COMMITMENT TO A SUITABLE TECHNOLOGY DEVELOPMENT PROGRAM.
4 IF SPECIFIC ADVANCED REACTOR DESIGNS WITH SOME OP ALL OF THE ABOVE OF THE FOREGOING ATTRIBUTES ARE BROUGHT TO THE NRC FOR COMMENT AND/0R EVALUATION, THE COMMISSION CAN DEVELOP
_-_____-.___ _._ _ _ ___..__ _ ____.__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ ________._i_._..___
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l' PRELIMINARY DESIGN SAFETY EVALUATIONS AND LICENSING CRITERIA FOR THEIR SAFETY RELATED ASPECTS.. COMBINATIONS OF SOME OR ALL OF THE'ASGVE ATTRIBUTES MAY HELP OBTAIN EARLY LICENSING APPROVAL WITH MINIMUM REGULATOPY BURDEN. DESIGNS WITH SOME OR ALL OF THESE ATTRIBUTES APE ALSO LIKELY TO BE MOPE PEADILY UNDERSTOOD BY THE GENERAL PUBLIC. INDEED, THE NUMBER AND NATURE OF THE REGULATORY REQUIREMENTS MAY DEPEND ON THE EXTENT TO WHICH AN INDIVIDUAL ADVANCED REACTOR DESIGN INCGPPORATES GENERAL ATTRIBUTES SUCH AS THOSE LISTED ABOVE. HOWEVER, UNTIL SUCH TIME ,
AS CONCEPTUAL DESIGNS APE SUBMITTED, THE COMMISSION BELIEVES THAT PEGULATORY GUIDANCE MUST BE SUFFICIENTLY GENERAL TO AVOID
- PLACING UNNECESSARY CONSTRAINTS ON THE DEVELOPMENT OF NEW DESIGN CCNCEPTS.
i TO PROVIDE FOR MORE TIMELY AND EFFECTIVE REGULATION OF ADVANCED PEACTORS, THE COMMISSION ENCOURAGES THE EARLIEST POSSIBLE l'
INTEPACTION OF APPLICANTS, VENDORS, OTHEP GOVERNMENT AGENCIES, i'
AND THE NRC TO PROVIDE FOR EARLY IDENTIFICATION OF REGULATORY REQUIREMENTS FOR ADVANCED REACTORS, AND TO PROVIDE ALL INTERESTED PARTIES, INCLUDING THE PUBLIC, WITH A TIMELY, INDEPENDENT ASSESSMENT OF THE SAFETY CHARACTERISTICS OF ADVANCED [
PEACTOR DESIGNS, SUCH LICENSING INTERACTION AND GUIDANCE EARLY <
- IN THE DESIGN PROCESS, WILL CONTRIBUTE TOWARD MINIMIZING l COMPLEXITY AND ADDING STABILITY AND PREDICTABILITY IN THE
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- LICENSING AND REGULATION OF ADVANCED REACTORS.
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J VHILE THE NRC ITSELF DOES NOT DEVELOP NEW DESIGNS, THE CcMMISSION INTENDS TO DEVELOP THE CAPABILITY FOR TIMELY ASSESSMENT AND RESPONSE TO INNOVATIVE AND ADVANCED DESIGNS THAT J
MIGHT SE PPESENTED FOR NRC REVIEW. PRIOR EXPERIENCE HAS SHCWN THAT FEW REACTCP DESIGNS -- EVEN VARIATICNS OF ESTABLISHED
, DESIGMS -- MAY INVOLVE TECHNICAL PROBLEMS THAT MUST BE SOLVED IN 4
GRDER TO ASSURE ADEOUATE PROTECTION OF THE PUBLIC HEALTH AND SAFETY, THE EARLIER SUCH DESIGN PROBLEMS ARE IDENTIFIED, THE EARLIER SATISFACTORY RESOLUTION CAN BE ACHIEVED. PPOSPECTIVE APPLICANTS ARE PEMINDED THAT, WHILE THE NRC WILL UNDERTAKE TO REVIEW AND COMMENT ON NEW DESIGN CONCEPTS, THE APPLICANTS ARE RESPONSIBLE FOR ALL DOCUMENTATION AND PESEARCH NECESSARY TO SUPPOPT ANY SPECIFIC LICENSE APPLICATION. (NRC RESEARCH IS CONDUCTED TO PROVIDE THE TECHNICAL BASES FOR PULEMAKING AND t
REGULATORY DECISIONS; TO SUPPORT LICENSING AND INSPECTION ACTIV-ITIES; AND TO INCREASE NRC'S UNDERSTANDING OF PHENOMENA F0P WHICH ANALYTICAL METHODS ARE NEEDED IN REGULATORY ACTIVITIES).
DURING THE INITIAL PHASE OF ADVANCED REACTOR DEVELOPMENT, THE COMMISSION PARTICULARLY ENCOURAGES DESIGN INNOVATIONS WHICH
, ENHANCE SAFETY AND RELIABILITY (SUCH AS THOSE DESCRIBED'ABOVE)
AND WHICH GENEPALLY DEPEND ON TECHNOLOGY-WHICH IS EITHER PROVEN OR CAN BE DEMONSTRATED BY A STRAIGHT-FORWARD TECHNOLOGY DEVELOPMENT PROGRAM. IN THE ABSENCE OF A SIGNIFICANT HISTORY OF OPERATING EXPERIENCE ON AP ADVANCED CONCEPT REACTOR, PLANS
t i FCP INNOVATIVE USE OF PROVEN TECHNOLOGY AND/0F NEW TECHNOLOGY !
DEVELOPMENT PRCGRAMS SHOULD BE PPESENTED TO.THE NRC FOR REVIEW AS EARLY AS POSSIBLE, SO THAT THE NRC CAN ASSFSS HOW THE PPDPOSED PROGPAM MIGHT INFLUENCE REGULATORY RECUIREMENTS. TO. !
ACHIEVE THESE BRCAD OBJECTIVES, AN ADVANCED REACTORS GRCUP HAS :
BEEN ESTABLISHED IN THE OFFICE OF FUCLEAR REACTOR REGULATION, l THIS GROUP WILL BE THE FOCAL POINT FOP NRC INTERACTION WITH THE ;
DEPARTMENT OF ENERGY, PEACTOR DESIGNERS AND POTENTIAL APPLICANTS, AND WILL COORDINATE THE DEVELOPMENT OF REGULATORY t
CRITERIA AND GUIDANCE FOR PROPOSED ADVANCED REACTORS. IN i ADDITION, THE GROUP WILL MAINTAIN KNOWLEDGE OF ADVANCED PEACTOR DESIGNS, DEVELOPMENTS AND OPERATING EXPERIENCE IN OTHER j COUNTRIES, AND WILL PROVIDE GUIDANCE ON AN NRC-FUNDED ADVANCED !
REACTOR SAFETY PESEARCH PROGRAM TO ENSURE THAT IT SUPPORTS, AND IS CONSISTENT WITH, THE COMMISSION'S ADVANCED REACTOR POLICY. '
THE ADVANCED REACTORS GROUP WILL ALSO PROVIDE GUIDANCE REGARDING THE TIMING AND FORMAT OF SUBMITTALS FOR PEVIEW, THE ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS) WILL PLAY A SIGNIFICANT ROLE IN REVIEWING PROPOSED ADVANCED REACTOR DESIGN CONCEPTS AND SUPPORTING ACTIVITIES. [
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t COMMISSION POSITION PEGARDING POLICY STATEFENT GUESTIONS SIX OUESTIONS PFPTAINING TO THE PROPOSED POLICY FOP ADVANCED PEACTORS WERE INCLUDED FOR COMMENT IN THE ORIGINAL POLICY STATEMENT. THE PUBLIC PESPCNSES TO THESE QUESTIONS ARE SUMMAPIZFD IN THE "ABSTPACT OF CCMMENTS" SECTION. AFTEP CAREFUL CCNSIDEPATION OF THE PUBLIC COMMENTS THE COMMISSION POLICY WITH
, REGAPD TO THE ISSUES RAISED IN EACH QUESTION IS AS FOLLOWS:
OUESTION 1. SHOULD NRC's PEGULATORY APPECACH BE REVISED TO REDUCE DEPENDENCE ON PRESCRIPTIVE REGULATIONS ,
AND, INSTEAD, ESTABLISH LESS PPESCRIPTIVE DESIGN l
CBJFCTIVES, SUCH AS PERFORMANCE STANDARDS? IF SO, IN WHAT ASPECTS OF NUCLEAR POWER PLANT DESIGN (FOR EXAMPLE, REACTOR CORE POWER DENSITY, REACTCR CORE HEAT PEMOVAL, CONTAINMENT, AND SITING) MIGHT THE PERFORMANCE STANDARDS APPROACH BE APPLIED i MOST EFFECTIVELY? HOW COULD IMPLEMENTATION OF THESE PERFORMANCE STANDARDS BE VERIFIED?
COMMISSION RESPONSE MANY OF THE CCMMISSION'S EXISTING REGULATIONS, CRITERIA, AND GUIDELINES'ARE OF A NONPRESCRIPTIVE NATURE, AND THE EXTENT TO WHICH THE COMMISSION'S PROPOSED SAFETY GOALS (WHICH ARE ALSO OF 1
, , . - _ _ . . . . , - . , _. .- ..m _ . _ _ _ _ . _ -, , ,
i I A NONPRESCRIPTIVE NATURE) WILL BE USED_IN THE REGULATION OF NUCLEAR REACTORS IS CURRENTLY BEIFG EVALUATED. IN THE PEVIEW AND REGULATION OF ADVANCED REACTORS THE COPMISSION INTENDS TO MAKE USE OF EXISTING AND FUTUPE PC.GULATIONS WHERE THEY ARE APPLICABLE TO ADVANCED REACTOPS. MANY SUCH REGULATICNS ARE i
EXPECTED TO BE OF A NONPRESCoIPTIVE NATURE. THE APEAc WHE7E EXISTING REGULATICNS AND GUIDELINES WOULD BE USED INCLUDE:
QUALITY ASSURANCE, EQUIPMENT GUALIFICATION, EXTEPNAL EVENTS, i SABOTAGE, FIRE PROTECTIOM, RADIATION PROTECTION, AND OPERATOR TRAINING AND QUALIFICATION. IN DEVELOPING ADDITIONAL CRITERIA
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AND GUIDANCE TO ADDPESS THOSE CHARACTERISTICS WHICH DIFFER FROM i LWRs, LESS PPESCRIPTIVE CPITERIA WILL BE CONSIDERED. THE USE OF ,
t LESS PPESCRIPTIVE CRITERIA WILL DEPEND UPON THE DESIGN IN ,
QUESTION AND THE ABILITV TO VERIFY COMPLIANCE WITH THE CRITERIA.
ADVANCED REACTOR DESIGNERS ARE ENCOURAGED AS PART OF THEIR ;
l DESIGN SUBMITTALS TO PROP 3SE SPECIFIC PEVIEW CRITERIA OR NOVEL i
REGULATORY APPROACHES WHICH NRC MIGHT APPLY TO THEIR DESIGNS.
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CUESTION 2. SHOULD THE REGULATIONS FOR ADVANCED REACTORS REQUIRE MORE INHERENT SAFETY MARGIN FOR THEIR ,
DESIGN? IF S0, SHOULD THE EMPHASIS BE ON PPOVIDING FEATURES THAT PERMIT MORE TIME FOR ;
OPERATOR RESPONSE TO 0FF-NORMAL CONDITIONS, OR L
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SHOULD THE EMPHASIS BE ON PROVIDING SYSTEMS THAT APE CAPABLE OF FUNCTIONING UNDER CONDITIONS THAT EXCEED THE DESIGN BASIS?
I r COMMIssten RESPONSE ,
P THE COMMISSIOM ENCOURAGES THE INCORPCPATION OF ENHANCED MARGINS 0F SAFETY IN ADVANCED DESIGNS AND WILL ENCOURAGE THE USE OF l
! DESIGNS THAT ACCOMPLISH THEIP SAFETY FUNCTIONS IN AS RELIABLE AND SIMPLIFIED A FASHION AS PRACTICAL. THE COMMISSION CONSIDERS i INHERENT OR PASSIVE SAFETY SYSTEMS TO HAVE THE POTENTIAL FOR !
a HIGH PELIABILI~.Y AND ENCOURAGES THE CONSIDERATION OF SUCH MEANS $
I (IM LIEU OF ACTIVE SYSTEMS) IN ADVANCED DESIGNS.-
TO ENCOURAGE SUCH ACTION THE COMMISSICN, IN ITS REVIEW OF THESE ADVANCED DESIGNS, WILL LOOK FAVORABLY ON DESIGNS WITH GREATER SAFETY MARGIN AND/0R HIGHLY RELIABLE SAFETY SYSTEMS. SUCH [
DESIRABLE FEATURES CAN BE DESIGN-RELATED OP CAN TAKE THE FORM OF- l t
REDUCED ADMINISTRATIVE REQUIREMENTS.
QUESTION 3. SHOULD LICENSING REGULATIONS FOR ADVANCED REACTORS MANDATE SIMPLIFIED DESIGNS WHICH REQUIRE THE FEWEST OPERATOR ACTIONS, AND THE MlHIMUM NUMBER OF COMPONENTS NEEDED FOR ACHIEVING AND MAINTAINING SAFE SHUTDOWN CONDITIONS, THEREBY
t FACILITATING CPERATOP CCMPPEHEMSION AND PELIABLE -
SYSTEM FUNCTION FOP CFF-NORMAL CONDITIONS?
COMMISS!cN RESPONSE e THE COMMISSION WILL ENCOURAGE DESIGNS WHICH ARE SIMPLEP AND MORE RELIABLE IN ACCOMPLISHING THFIP SAFETY FUNCTIONS, WHILE CURRENT t
, i GENEPATION NUCLEAR POWER PLANTS, IN OPEPATION OR UNDER [
E CONSTRUCTION REPRESENT NO UNDUE RISK TO EITHER THE PUBLIC OR THE ;
, ENVIRONMENT, THE COMMISSION BELIEVES THAT REACTORS WITH IMPROVED SAFETY CHAPACTERISTICS CAN AND WILL BE DEVELOPED. SUCH IMPROVED f SAFETY CHARACTERISTICS SUPPORT THE COMMISSION'S LONG-RANGE GOAL
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OF MINIMIZING THE RISK TO THE PUBLIC AND THE ENVIPONMENT THROUGH THE "ALARA" APPP0ACH, .
CUESTION 4. SHOULD THE NRC DEVELOP GENERAL DESIGN CRITERIA ,
FOR ADVANCED REACTORS BY MODIFYING THE EXISTING REGULATIONS, WHICH WERE DEVELOPED FOR THE CURRENT '
4 GENERATION OF LIGHT WATER' REACTORS, OR BY '
4 DEVELOPING A NEW SET OF GENERAL DESIGN CRITERIA APPLICABLE TO SPECIFIC CONCEPTS WHICH ARE BROUGHT
- BEFORE THE COMMISSION?
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CcMMIsSION RESPONSE IN DEVELOPING LICEPSING CRITEP!A FOR ADVANCED REACTORS, THE COMM I S S t Ct' INTENDS TO BUILD UPON EXISTING REGULATIONS WHEREVER PPACTICAL, AS DISCUSSED It' THE PESPGNSE TO CUESTION NO, 1. IN FOLLOWING THIS APPROACH, IT IS THE CCMMISSION'S INTENT TO ESTABLISH, FOR EACH DESIGP REVIEWED, THE LICENSING CRITERIA THAT APPLY TO THAT DESIGN. AS STATED IN THE RESPONSE TO QUESTION NO, 1, THESE CRITEP!A WILL BE A COMBINATION OF APPLICABLE LWR CPITERIA AND CRITERIA DEVELOPED TO ADDRESS THE UNIQUE CHAPAC-TEPISTICS OF THAT DESIGN, REACTOR DESIGNERS ARE ENCOUPAGED TO PROPOSE SPECIFIC CPITERIA AND NOVEL REGULATORY APPROACHES WHICH MIGHT APPLY TO THEIR DESIGN, OUESTION 5. SHOULD THE NRC FAVOR ADVANCED REACTOR DESIGNS THAT CONCENTRATE THE PRIMARY SAFETY FUNCTIONS IN VERY FEW LARGE SYSTEMS (RATHER THAN IN MULTIPLE SUBSYSTEMS), THEPEBY MIN!f11 ZING THE NEED FOR COMPLEX BENEFIT AND COST BALANCING IN THE ENGINEERING 0F SAFE REACTORS?
CCfiMISSION RESPONSE
'/HILE THE NRC WILL NOT NECESSARILY FAVOR ONE DESIGN APPROACH OVER ANOTHER IN PEGAPD TO THE NUMBER OF SAFETY SYSTEMS, THE NRC WILL ENCCURAGE THE USE OF SIMPLIFIED SYSTEMS AND SYSTEMS OF HIGH RELIABILITY FOR THE ACCOMPLISHMENT OF SAFETY FUNCTIONS.
QUESTION 6. WHAT DEGREE OF PP00F WOULD BE SUFFICIENT FOR THE NRCiTO FIND THAT A NEW DESIGN IS BASED ON TECHNOLOGY WHICH IS EITHER PROVEM OR CAN BE DEMONSTPATED BY A SATISFACTORY TECHNOLOGY DEVELOPMENT PROGRAM? FOR EXAMPLE, IS IT NECESSAPY OP ADVISABLE TO REQUIPE A PROTOTYPICAL ,
DEMONSTRATION OF AN ADVANCED REACTOR CONCEPT PRIOR TO FINAL LICENSING OF A COMMERCIAL FACILITY?
COMMISSION RESPONSE l
THE COMMISSION REQUIRES PROOF 0F PERF0PMANCE OF CERTAIN SAFETY-RELATED COMPONENTS, SYSTEMS OR STRUCTURES PRICP TO' ISSUING A LICENSE ON A DESIGN. FOR LWR'S THIS PROOF HAS TPADITIONALLY BEEN IN THE FORM OF ANALYSIS, TESTING, AND I
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.i j FESEARCH DEVELOPMENT SUFFICIENT TO D'EMONSTPATE THE PEPFORMANCE OF THE ITEM It' OUESTION. SIMILAP PRCOF OF PERFORMANCE FOR 4
i' CERTAIN COMPONENTS, SYSTEMS OR STRUCTUPES FOP ADVANCED REACTCRS ,
WILL ALSO BE REQUIRED. THE PE0VISITE PROOF WILL BE DESIGN-DEPENDEtlT . THEREFORE, THE CCMMISSION'S SPECIFIC ASS $SSMENT OF A i SAFETY TECHNOLOGY DEVELOPf'ENT PROGRAM FOR 'AN ADVANCED REACTOP DESIGN, OR OF THE POSSIBLE NEED FOR'A PROTOTYPICAL DEMONSTRATION 1 ,
0F THAT DESIGN CAN BE DETERMINED ONLY BY REVIEW OF A SPECIFIC
! DESIGN. HOWEVEP THE COMt11SSION-FAVORS THE USE OF PROTOTYPICAL DEMONSTRATION FACILITIES AS AN ACCEPTABLE WAY OF RESOLVING MANY 1
- SAFETY PELATED ISSUES.
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I FOR THE COMMISSION i
l 5AMUEL J. LlilLK SECRETARY OF THE COMit!SSION ,
?J DATED AT WASHINGTON, D.C. <'. '
^
THIS DAY OF APRIL, ]986 -
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Dissenting Views of Commissioner Asselstine I do not believe that this advanced reactor policy statement provides the sound regulatory basis needed to support a new generation of nuclear power plants in this country. This policy statement encourages, but does not require, safety improvements in advanced reactor design, and expresses a willingness on NRC's part to conduct safety reviews of advanced reactor design concepts so that NRC will be in a position to act on any future olant or design license application. The primary decision made in developing this policy is the commitment to maintain a small advanced reactor grcup within the Agency that would serve as the focal point for interaction with reactor design groups. However it appears that even this commitment may be in jeopardy _ given current budgetary constraints.
I believe that more is needed to articulate an effective regulatory policy and to ensure a successful program for future nuclear power plants in this country, whether those plants are of a type similar to current light water reactors or whether they are of more fundamentally different design. Such a policy should reconsider the Commission's regulatory practices of the 1 past thirty years. Those past practices can be characterized as primarily a reactive regulatory regime to what the designers propose. It leaves resolution of issues to what one industry executive has called the rough, tough surly competitive elements. Safety systems are limited becauselof cost considerations. Containment capabilities are minimized to reduce costs. Core power densities have been driven to the limits of materials capabilities and our understanding of decay heat removal phenomena. And J
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the balance of plant is . designed to lower standards than the reactor systems to minimize ccsts. These comcetitive forces are what led to the level of safety achieved in the current generation of nuclear powar clants and are in part responsible for the poor performance of some of our plants.
The NRC and .ACC 6e' fore it have oft.en avoided developing stringent spac Pfcations or design requirements because of a fear that if the Ccmmission were to be too specific in its reouirements, the energing [
industry night be slowed in its growth and innovation might be discouraged. ,
That argument might have had some validity in the 1960's and 1970's when the currei.t generation of reactors was being designed without the benefit of significant operating experience or data. However, now that we have considerable worldwide experience with a large variety of nuclear reactor designs,'I believe it is time for NRC to become more proactive in what it will require of future generations o# reactors.
Following the TMI-2 accident, the notion of a demarcation between the current generation of plants and a future generation of plants was raised, with the distinction that the latter would be' designed based on a ,
reformulation of the Siting Criteria and General Design. Criteria to reflect all that had been;1 earned over the years, 'Ir.cluding the broader lessons of TMI-2. Thus, the TMI Action Plan was developed with the current generation of plants in mind, leaving open the question of possible broader changes for a future generation of plants. One such broad change could be to go beyond the so-called single failure criterion which experience shows may
rot be serving us well. The June 9, 1985 accident at Davis-8 esso is a case in point where 14 separate failures occurred.
"any foreign ccuntries are requiring four independent trains of safety systens whereas NRC reouires only two. When NRC reviews advanced designs ,
such as the one being fointly developed by a lj.S. vendor and a foreign country, the NRC staff does not require as prudent additional safe'y i
features being required by the _ foreign country. Rather, Commission practices and procedures require a cost-benefit analysis to ,iustify any additional safety feature. This analysis is typically incomplete and often crude. Furthermore, the Commission gives little consideration to the enormous uncertainties in reactor risks in its decisionmaking process.
This approach to reactor safety needs improvement.
There has been insufficient thought and effort in developing a map for the future. The Advanced Reactor Policy Statement provides no guidance on what l
containnent capabilities will be required; on whether the single failure criterion is adequate for the future; on acceptable core power densities !
(an issue which has significant bearing on the core meltdcwn risks to the public); and on the root causes of the core meltdown risks that might be addressed by design improvements in a future generation of reactors. Nor is there guidance on what standards the balance of plant must meet.
Nothing is said about the fuel cycle and the process for licensing the fuel cycle associated with some of the advanced designs currently being examined. For example, when and in what way will the Commission reopen the aborted proceeding on plutonium recycle. And, finally the Commission gives
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essentially no guidance on whether a prototypical plant will be required 3 before allcwing widespread use of that design. I would have expected that
DC would approach a future generation of nuclear power plants with an attitude of correcting past weaknesses. Unfortunately, the Advanced -
Deactor Policy Statement does not reflect that kind of attitude.
Cther countries with extensive nuclear power programs appear to be ,
1 designing, constructing, operating and maintaining better nuclear power plants than those of this country. Foreign countries are demanding more safety and reliability in their current generation of plants than the flRC is requiring of the U.S. olants. Yet, this Advanced Reactor Policy Statement accepts the next generation of U.S. power plants if such a design l provides a level of safety equivalent to that achieved in the U.S. designs ,
that were completed over 10 years ago. I do not think such a policy serves the country well. My concern is not merely that we should keep up with others. Rather, my concern is that the current generation of plants is ,
I still surprising us in their performance. As the Commission has recently acknowledged to the Congress, the current generation of nuclear power plants in this country can best be characterized as a complex technology
- that is not fully mature. There' remain great uncertainties in the level of .
risk they pose to the public. In such circumstances, I believe prudent i
decisionmaking should come down on the side of improved safety, not only for the current generation of plants but for the next generation as well. .
l If there is to be a future generation of nuclear power plants and if the nuclear option is to be an important element of the nation's future energy
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mix, then the NRC, the vendors, the utilities, and the Congress must ensure that the next generation of power plants is substantially better than the current generation. The next generation of plants should be more reliable, r more forgiving, simpler, easier to construct, easier to operate, and easier to maintain than the current generation. Any design that does rot accomplish this is not acceptable in my view. I say this for a straight #orward reason. We cannot afford to will to the future reactor designs that have a fifty percent chance of a core meltdown every ten to ;
twenty years in a population of 100 reactors. We should not will to the
'uture the great uncertainties in safety levels that exist today. Nor should we will to the future consumer reactor designs that have a 50 to 60 percent capacity factor.
We must step back and examine the strengths and weaknesses of past and current designs and the approaches taken in getting where we are today.
Only then, in my view, can we intelligertly' map a course for the future. I am encouraged that there is a segment within the industry that is undertaking a fresh look at the nuclear technology. The forward-looking members of the industry are attempting to generate a set of requirements f
that, from the standpoint of the utilities, must be' met before utilities will consider placing new orders. I find it disappointing that the NRC is unwilling to generate a set of safety requirements for the next generation of power plants.
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