ML20238C741
| ML20238C741 | |
| Person / Time | |
|---|---|
| Issue date: | 10/20/1987 |
| From: | NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | |
| References | |
| FRN-53FR32060, RULE-PR-52 NUDOCS 8712310189 | |
| Download: ML20238C741 (102) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION ORIGINAL 4';
Office of Nuclear Regulatory Research e.
In the Matter of:
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Public Meeting on Standardization Policy
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Place:
Bethesda, Maryland Date:
, October 20, 1987 Heritage Reporting Corporation Official Reporters 1220 L Street. N.W.
8712310189 871020 Washington, D.C. 20005 23 0 9
PDR (202) 628 1888
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1 UNITED STATES NUCLEAR REGULATORY COMMISSION 2
3 NUCLEAR POWER PLANT STANDARDIZATION WORKSHOP 4
5 Tuesday 6
October 20, 1987 7
Hyatt Regency Cabinet Room 8
Bethesda, Maryland 9
10 The above-entitled matter came on for hearing, 11 pursuant to notice, at 9:07 a.m.
12 13 14 PRESENT:
15 ERIC S.
BECKJORD JERRY N. WILSON 16 LESTER S. RUBENSTEIN STUART A.
TREBY 17 STEVEN F. CROCKETT JAMES W.
VAUGHAN, JR.
18 RICHARD B.
PRIORY JACK DEVINE 19 EDWARD SCHERER i
WILLIAM JOHNSON l
20 ROBERT C. MITCHELL I
EDWARD SMITH 1
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I 22 23 24 25 Acme Reporting Company (202) 628-4888
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PROCEEDINGS 2
MR. BECKJORD:
Good morning.
My name is Eric 3
Beckjord, and I am the Director of the Office of Nuclear I
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4 Regulatory Research at NRC.
I want to welcome you to'this 1
5 Workshop on Standardization.
And'I am going to'give some j
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introductory remarks on this subject.
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It is certainly no surprise to you that the Nuclear 8
Regulatory Commission believes that standardization of nuclear 9
power plants is an important initiative that can improve 10 safety, reliability, and availability of future nuclear plants.
11 Standardization policy has the goal of achieving certification 12 of plants proposed for licensing.
This means that all of the 13 regulatory requirements would be established before 14 construction would begin, and that design would also be 15 complete.
16 I think that many benefits can derive from 17 certification including planning and project management that 18 are important not only to assuring safety but also to 19 controlling project construction costs, and that is an 20 essential requirement for the survival and growth of the 21 nuclear industry.
22 But the purpose of today's meeting is somewhat less 23 global than that.
It is to establish a forum for discussion of 24 plant s t:andardiza t ion, t.o exchant19 views, and to get your input 25 on the issues that will be important to the implementation of Heritage Reporting Company (202) 628-4888
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standardization.
And what is also important is that we want to 2
get your views to include them in the consideration of the 3
rules that we are preparing for design certification.
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4 The right people from NRC are here for the J
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discussion.
Jerry Wilson is here of the Research Office staff, 6
who is responsible in research for standardization policy.
7 Less Rubenstein, who is Director of Standardization and 8
Non-Power Reactors in NRR.
And Stuart Treby, Assistant General 9
Counsel for Rulemaking and Fuel Cycle.
10 Now there are some housekeeping announcements that I 11 wanted to make.
There are copies of the agenda and NRC's 12 materials for the presentation.
They are available at the 13 registration table.
Although I did not see them, they are l
14 there now.
15 If you wish to make a presentation, please see Mr.
16 Hardin at the registration table.
And I note that there will 17 be a transcript of this meeting for the use of the staff and 18 for your own use if you want to see what was actually said in 19 the meeting.
20 Accordingly, please use the podium for your 21 presentation.
And if you are asking a question, please state 22 your name and affiliation.
23 I am confident that this meeting will be productive 24 and successful for all of you who are here and are interested 25 in this subject.
And I am going to ask Jerry Wilson to take Heritage Reporting Company (202) 628-4888
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over, and he is going to talk about and summarize the 2
standardization policy statement.
3 MR. WILSON:
Thank you, Dr. Beckjord.
I am going to 4
make a brief summary this morning on the standardization 5
policy.
We want to leave plenty of time to talk about our 6
proposed rulemaking package which is of primary interest today.
7 Standardization has been an issue of primarytinterest 8
to the Commission for many years.
The initial policy statement 9
was issued in 1972 and clarified in 1973 and 1974.
Our policy 10 was reformed in the 1977 and 1978 time frame, and the revised 11 policy was published in the Federal Register on September 15th.
12 (Slide.)
13 Why did the Commission revise their standardization 14 policy?
Well, the NRC staff has had considerable experience in 15 implementing the various standardization concepts that were set 16 forth in the 1978 policy statement.
There were many issuances 17 of preliminary design approvals, construction permits,'and 18 final design approvals utilizing the reference plant concept.
19 In addition, there were several construction permits issued 20 under the duplication concept, and three of the construction 21 permits became operating licenses.
22 There were a number of plant replicate design 23 concepts that were the basis for the issuance of construction 24 permits that no Obs have resulted.
Also a manufacturing I
25 license was issued in 1982 for eight units to be built by j
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1 Westinghouse.
2 The severe accident policy statement affected 3
standardization in that additional requirements were identified 4
for new designs.
These requirements are set forth in the 5
revised policy statement.
6 The Commission has also proposed legislation to 7
Congress that would encourage the standardization concept.
8 That legislation includes issuance of a combined construction 9
permit and operating license, issuance of a site permit prior 10 to submission of an application for a construction permit or 11 combined construction permit and operating license, and 12 issuance of a design certification prior to submission of an 13 application for a construction permit or combined construction 14 permit and operating license.
15 As a result of these factors and the current interest 16 in design certification, the Commission decided to update the 17 1978 policy statement with a revised policy statement.that 18 reaffirmed their support for standardized plants.
19 (Slide) 20 The 1987 policy statement encourages standardization 21 by certification of a complete reference design, and it 22 discourages the other standardization concepts.
Other 23 important points of the policy is that it should be a mature 24 design that is essentially complete in scope and level of 25 detail.
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(Slide) 2 The 1987 standardization policy is consistent with 3
the safety goal, the severe accident and advanced reactor 4
policy statements.
The Commission intends to restrict 5
back-fits and other changes to the certified design, and any 6
changes would be applied uniformly to all plants.
7 And finally, the Commission plans to implement ~the 8
revised standardization policy with proposed regulations that 9
will address licensing reform and design certification.
Mr.
10 Treby will discuss these regulations.
11 Our next speaker is Mr. Rubenstein, who will discuss 12 the status of our current design certification activ3 ties.
13 MR. RUBENSTEIN:
Thank you, Jerry.
I am very pleased 14 to be here this morning to discuss the implementation of our 15 NRC standardization policy, and to represent both NRC'and in 16 particular NRR in reaffirming the Commission's intent to make 17 resources available on a priority basis to facilitate the' 18 review of the referenced systems.
I have a very short formal 19 presentation, and it is essentially limited to two viewgraphs.
20 (Slide) 21 This is a very simple viewgraph with a very limited 22 point to it.
With it, I hope to bring some precision to the 23 terms that we bandy about in terms of advanced plants, future 24 p.iants, reference designs, and evolutionary designs.
When one i
25 talks about the future plants, all plants here are future j
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plants.
2 When one talks in particular about advanced plants, 3
which to a large degree are sponsored by DOE andithe industry.
4 in general, which deal primary with the future which is a.
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5 threshold perhaps the.1990s, one can characterize these as-6 saying these are probably not based on proven operating
-7 technology certainly in the United States.
And I do not mean 8
by that to slight the efforts of the FFTF or the other LMFBR 9
things, but I mean in a commercial sense.
10 The second group of plants, the standardized 11 evolutionary reference designs, these are those which are based 12 on the proven LWR technology..And so when I talk about it, 13 when I talk about an advanced plant and I go to the ACRS and I 14 will talk about an advanced plant or a reference plant, the 15 advanced plants are those on the top, and the reference 16 standard designs are on the bottom.
17 And most of these standard designs are consistent or 18 all are mostly consistent with the EPRI ALWR design 19 construction guidelines.
And I believe that Jack DeVine may 20 talk about this at a later point today.
These designs in and 3
21 of themselves represent a formal disciplined utility industry 22 effort to factor the experience of the last approximately.
23 twenty years of design construction and safe operation.
j 24 So with the experience both in design, construction, 25 and operation of the industry and the formalization in the ALWR l
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8 1-guidelines and the experience in the design and the vendors, 2
these. plants are a good evolutionary step based on the. current 3
proven ALWR technology.
So these are the. plants which I will 1
4 be talking about which are in NRR.
The conceptual review of-5-
'the advanced plants is done by Tom King in the Office of 6
Research.
7 So in summary, future plants terminology captures 8
them all.
Advanced plants are in Research.
They are.
9 conceptual reviews.
They are to a large degree supported by.
10 DOE.
The others are in the design stage.
They are in NRR for 11 licensing.
12 And my next viewgraph will discuss a little about the i
13 sense of the status and the timing for these to place those 14 reference plants, these evolutionary plants, in perspective 15 with the rules and the policios that you will hear today.
16 (Slide) 17 Now I have a limited number of points that I want to
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18 make with this viewgraph.
First of all, I want to say that 19 both at GE and at combustion engineering that FDA submittals I
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We are having kick-off meetings this week and next 21 respectively.
And the NRR staff is getting involved in 22 particular with the reviews.
23 In the case of Westinghouse, I think that the review 24 has been revitalized.
It is a PDA review.
And I view 25 standardization as a team effort.
I have four project managers Heritage Reporting Company l
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assigned to it, one for ALWR and one for each of the reference 2
plants.
They are here today.
They can go during the breaks 3
into discussions about specifics of the schedule, but I want to 4
give with my talk just a sense of the schedule and the status.
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As I said, on the top line is submittals.
They are 6
in fact in-house being dealt with.
Reviewers are assigned and' 7
designated, and the kick-off overall executive and staff 8
briefings are in progress.
Recently, we made some progress 9
with the first chapter of the ALWR.
That has gone through with 10 the ACRS Subcommittee, and the draft SCR is published.
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Now the important point of the viewgraph is one looks 12 at this and sees that the draft SCRs are issued in an 1989 13 quote time frame, in an 1989 quote time frame.
And the final 14 SERs which I would presume as experience as dictated in the 15 past would be the staff's main testimony going into a 16 rulemaking is on a 1990-1991 time frame.
17 Now one could notice that ALWR is a 1991 time frame, 18 but I have been assured and I see the results of close 19 interaction between the designers and the EPRI program and the l
20 industry, so that the design while in fact on my schedule may 21 precede some of the final approvals of the SER for the ALWR are 22 consistent with those things.
23 And of course, one should note that I have listed 24 Westinghouse PDA.
They will cpeak for themselves today, but 25 they formally intend to I believe go for the FDA and design Heritage Reporting Company (202) 628-4888
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certification, and that is the way that our plans ere-going.
2 And the bottom line is, and we will discuss it at 3
some great length, with Mr. Treby and Crockett that the design 4
certification including rulemaking is in the 1991-1992 time 5
frame.
So we are talking about the evolutionary plants for the 6
1990s.
7 Now one other thing which I care to say is that one 8
of the uncertainties I am sure in your mind is how does one 9
implement the severe accident policy on these existing plants 10 and on the evolutionary designs.
And I believe that this is an 11 area that Research is now starting to go, and it will mean that 12 it is a very tight schedule.
It is consistent with the kinds 13 of schedule that we have for these numbers.
And it will mean 14 on your part a lot of vigilance and interaction with Research.
15 And Dr. Rosztoczy is here, and he can answer some general 16 questions about the vision that we have to make the schedule 17 converge 1 August with your accident requirements.
18 And it is a large role for you to play where you have 19 to keep up to date and participate, so that you will know what 20 the requirements are.
So that when 1990-1991 rolls about, it 21 will all converge with some sort of common consensus 22 understanding of what it requires to license these plants to a 23 rulemaking process.
24 Now the dates are because of the nature of the 25 submittals of many of your systems come in cytr a year or time Heritage Reporting Company (202) 628-4888
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period, so some of the deths are approximate.
The viewgraph is "I
2 designed merely to give yvu a sense of the status, to give us 3
our target for thes 1990s, 1990-1991 certification.
And I hop 5 o o 4
to say Ahat NRR is serious about it, and we want to wod$ with i
5 you.
That is all thht I have to say.
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6 MR. TREBY:
Good morning.
My name is Stuart Tieby, A
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and I am the Ascistant General Counsel for Rulemaking anL Friel e i e
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8 Cycles.
And I, too, am happy to be here today.
I vieWtsis aM w,
9 a very. exciting way to get some of your input as we are in the 10 midst of developing regulations.
It is not something that'we 11 have done a lot of us, and I think that we are very interested 12 in seeing how it is going to work.
13 My division is charged with the promulgation of a \\
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4 14 rule that will implenent the policy statement which the 15 Commiss. ion has put. out on standardization.
And I together with i
16 Steve Crockett, who is also here, Steve in the attorney in OGC s
17 who is working on the rule nr d who ir going to 9ake ua
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x 18 presentation as'soop as'] am f.inished, will go into tscre detail 19 as to what our current' thinking about che rule is, t
20 What I voald 11ba to indicate at this time though is I
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21 trat we are busily wortang en a proposed rule to imp 1w ent the 22 Commission's policy.
I would like to inoicate to you that this 23 rule has a very high priority in my office.
It is my intention
.i 24 that we are going to be moving along'on a fairly fast ' t. rack 25 with regard to development of this proposed rule.
I would like Heritage' Reporting Company (202) 628-4888 m _.
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to talk for a moment about timing.
2 At this workshop, we are seeking to get your input.
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3 And also, I would like to indicate to you that in the Federal 4
Register notice that put out the policy statement and mentioned 5
this meeting today, it indicated that written statements could 6
be submitted until October 30th.
So if there are additional 7
comments that any of you wish to make after we have had this 8
meeting and you have had some time to reflect on them, we would 9
certainly be receptive to getting those comments on the 30th.
10 It is our expectation that we will be publishing a 11 proposed rule before the end of calendar 1987.
The rule will i
12 be published for notice _ad comment, and we would expect that 13 we should have a final rule to be published by the fall of 14 1988.
15 Right now, the rule is in draft form.
There are some 16 options that we are still considering.
And when Steve Crockett d
17 goes through the rule, he w!!! identify eome of those for your l
18 consideration.
19 But I would like to reemphasize what Dr. Beckjord 20 stated at the beginning.
And that is what we welcome your 21 input, and that we are going to be very receptiva to your 22 comments and suggestions that you make this morning.
And we 23 hope that you will be forthcoming with them.
24 On the other hand, we also would like to indicate 25 that we have been thinking about this for quite awhile.
And we Heritage Reporting Company (202) 628-4888 s
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do have some concept in mind, and we want to share that 2
thinking with you.
3 First, we are proposing that this will take the form 4
of a new part to our regulations which at this time we have 5
designated as Part 52.
In this part, we are seeking to put 6
into place as much of the Commission's legislative proposal 7
that has been submitted over the past five years to Congress as 8
possible under the current statute.
9 We believe that a great deal of the legislative 10 proposal can be promulgated as a rule, but we are going to 11 continue to seek congressional affirmation of the 12 standardization policy.
13 As Steve Crockett is going to discuss in more detail, 14 proposed Part 52 will provide for three licenses.
First, an 15 early site permit by which we are hoping that we can 2icense 16 some sitos that can be banked.,
And a design certification 17 license in which a final design will have been reviewed end 18 certified by the staff.
19 And third, seme sort of combined licent;e, that we 20 hope.
Lince we wi13 have the final design in effect, we are 21 hoping that ae will be close to or at the FSAR stage.
We think 22 that we ought to be able to litigate all the kinds of issues 23 that we normally litigate at the construction permit stage and 24 the operating license state at one hearing.
25 The only things that I can think of that we would not Heritage Reporting Company (202) 628-4888 i
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be able to litigate would perhaps be how the QA program has 2
operated, since the plant has not yet been constructed, and 3
whether the as-built plant, in fact, conforms to the FSAR.
4 Again, since the thing has not yet been constructed, we will 5
have to wait for that.
6 But those are generally the matters that our regional 7
offices, as part of their inspection program, look into.
So, 8
we're hoping that at this point, when we hold the hearings on 9
what we would call a combined license, that we would be able to 10 put to that most of the issues that normally are raised.
11 The centerpiece of the rule is the design 12 certification.
This, really, is somewhat of an elaboration of 13 Appendix 0, as I am sure many of you are familiar with.
The 14 two-fold task of Part 53 will be, one, to issue the standards 15 for issuance and renewal of licenses, especially the design 16 certification, and second, to set forth the various procedures 17 that are necessary to cet us to that point.
That is, what the 18 contents of applications, requirements for hearings -- whether 19 they are mandatory or not -- what the role of the ACRS will be.
20 It w U 1 cover the question of fees, etcetera.
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21 There is a hand-out which has set forth in. sort of 22 outline-form the three licenses that I have made reference to.
I 23 That is, the early site permit, the design certification in i
I 24 this combined license.
Steve Crockett is going to discuss now 25 just what our thinking is with regards to proposed Part 52, and Heritage Reporting Company (202) 628-4888
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in particular, go through those hand-outs as sort of a guide to 2
his talk.
So, at this time, I would like to turn it over to 3
Steve Crockett.
4 MR. CROCKETT:
Thank you, Stu.
5 With Stu's introduction, I think we can begin right 6
in on the various elements of the rule.
I might add first, 7
though, that we are thinking largely on advancements on light-8 water reactors.
However, we are entirely open to the 9
possibility of adding a section to the rule which would provide 10 for proto-typical testing standards for designs that are not 11 simply evolutions of designs already in use.
You might keep 12 that in mind as I go through the elements of the rule.
13 The rule is, as Stu said, largely procedural.
14 However, now and then, we must cross over into matters of 15 substance, because matters of substance will determine the 16 course of procedures, quir,e often.
The three licenses that the 17 rule provices for are, ideally, to bE used together.
- However, 18 the rule will allow them to be used separately.
These are new 19 optiens, which we would hope that the industry would use 20 together, but nonetheless, each one of. the licenses does remain 21 useful, takan separately.
1 22 First, the early site permit.
The provisions of the 23 rule here are largely elaborations of Appendix Q to Part 50.
l 24 However, as you will see, it's quite different from Appendix Q l
25 in most respects, and particularly in respect to provisions for Heritage Reporting Company (202) 628-4888 u
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finality to any decision that the Commission makes with 2
reference to these early site permits.
3 And early site permit can be applied for without 4
there also being an application for a construction permit at 5
the same time.
An early site permit would authorize limited 6
work authorization at a site if an environmental impact 7
statement is complete.
The permit would also allow use of the 8
site for other purposes pending construction if those purposes 9
would be consistent with the assumptions which underlie the 10 grant of the permit to begin with.
Since these permits last 11 for some time, we must avoid freezing up the use of that land 12 if the land can be put to other uses consistent with the 13 eventual use of the land for a nuclear plant.
14 The applicants for an early site permit must be 15 potential Part 50 applicants.
I'm not sure that's much of a 16 restriction.
However, we feel it needs to be in there because 17 we're not sure precisely what our authority is under the Atomic 10 Energy Act to go around putting the Good Housekeeping Seal of 19 Approval on various pieces of land.
We think there probably 20 has to be some connection to che construction permit, and we 21 think in this case we think perhaps enough of a connection will 22 be established if the applicant for an early site permit is 23 also a potential applicant for a Part 50 construction permit or 24 a license.
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25 The content of the application.
Here are the Heritage Reporting Company l
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greatest differences with what is asked for in Appendix Q at 2
the moment.
The application should contain information on the 3
number, type, and power of facilities suitable for the site, 4
the type of cooling systems for each facility, the geological 5
and meterological characteristics of the site, an environmental 6
report as required by Sections 5145 and 5150 in 10-CFR, and 7
also information on amenability of the area to rapid 8
evacuation.
You'll see that a theme throughout the rule is the 9
settling of emergency planning considerations as early as 10 possible.
This is reflected in the early site permit by a 11 requirement that the application consider the amenability of 12 the surrounding area to rapid evacuation.
13 A hearing under Sub-part G, we believe, is mandatopy.
14 Since this is a Commission license, it would appear that under 15 the Atomic Energy Act, as it currently reads, a Sub-part G full 16 adjudicatory hearing wonad be nececaery.
Since the early site 17 permit crosses over into several safety quastions, we also 18 believe at the moment that ACRS review of Ltose safety issues 19 is mandatory also.
20 Fees for the review of there early site permits will 21 be deferred until the site is sctually roferenced by an 22 applicant for a construction perrait or a combined license, at l
23 which time some part of the fee would be due from the holder of 24 the permit.
Now, any fee provisions that we have right now are 25 a bit up for grabs as both Houses of Congress change from day i
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to day about various user-fee schemes to be imposed on the 2
Commission.
3 Also, we are in court, it seems, every other day on 4
various facets of these user fees.
So, any provision in the 5
rule right now for user fees is probably the most unsettled 6
part of the rule altogether.
However, it's our intent to try 7
to weave in something which would defer the charging of the 8
expenses of review until the licenses are actually put to use 9
by someone referring to them in a later application.
10 Now we come to a second important recurring theme:
11 namely, the finality of decisions on early site permits.
I 12 think it's true with all three of these licenses that the 13 finality provisions are stronger than anything that exists in l
14 current 10-CFR.
The formula for early site permit is the 15 formula that we are considering also for design certifications 16 and combined licenses.
Namely, the decisions made on issues in l
17 the course of a proceeding leading to the grant of an early 18 site permit are fir 31, except when the Commission determines on 19 the bas a of new information that adequate protection requires 20 ramo modification to those decisions.
21 Please don't ask me right now what adsguate 22 protection is.
We can come to that later.
23 The duration of the permit is ten years.
We are 24 certainly open to suggestions there.
Ten is not a magic 25 number.
It has to last for some length of time.
- However, i
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since we are dealing with pieces of land, and land changes 2
rapidly, or the circumstances of land change rapidly, it could 3
be argued that ten is too long.
I don't know; we are quite 4
open to suggestions.
5 The holder of a permit may apply for a renewal of the 6
permit, in which case a renewal would be granted once, for a 7
time between five and ten years.
The renewal will be granted 8
if the application shows that the site continues to comply with 9
the Atomic Energy Act, and the Commission's regulations.
We 10 believe that under the Atomic Energy Act, as it's currently 11 written, there must be an opportunity for a hearing on an 12 application for renewal.
However, we believe that the hearing l
13 could follow the renewal, and the timing of the hearing would 14 depend on a staff finding of whether there had been significant 15 changes at the site.
Of course, if there had been significant i
16 changes, the hearing would precede the grant of the renewal.
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77 Otherwise, it wauld follou the grant of the renewal.
18 You'll have an opportunity to ask questions about 19 each one of these major sections of the rule after 1 m l
20 finishea.
I'll go en now to design certification.
21 As Stu said, tais is in many ways the most important l
22 part of the rule.
It is in some respects an elaboration of 1
i 23 Section 7 of Appendix 0 to Part 50, and in some respects also 1
24 an elaboration of Appendix M to Part 50.
The idea is to embody 25 a complete design in a rule.
The meaning of " complete" will Heritage Reporting Company (202) 628-4888 1
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receive some clarification when I describe the contents of the 2
application.
3 The applicant for a design certification must hold an 4
Appendix 0 final design approval.
In other words, there must 5
be the staff's judgement first that the design is worthy of a 6
final approval, and then the Commission would also pass on the 7
certification.
The content of the application has been 8
described to some extent in the policy statement already.
The 9
policy statement's provisions on the content of the application 10 are actually derived from the relevant policy statements.
i 11 First, there should be an FSAR with all the 12 information that is usually contained in an FSAR, except for 13 things that obviously can not be presented by a designer in the 14 absence of an organization to operate the plant and a specific 15 site.
So, for instance, the application would not need to 16 contain information on the organization of the operating 17 organization, or on the current state of the environment around 18 the site where the plant might go.
l 19 There must be a PRA submit ted with the application,
?0 and the PRA shculd be strong en consideration of the 21 vulnerabilities of the design to severe accidents.
You may 22 recall that the policy statement on severe accidents, I think, 23 held open the possibility that an applicant for design approval 24 would not have to submit a complete PRA, and that the PRA work 25 could be done, or else completed, by an applicant referencing Heritage Reporting Company (202) 628-4888 L_____________
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the final design approval.
In the case of a design 2
certification, the rule would require a complete PRA with the 3
application.
4 The application should also, of course, demonstrate 5
compliance with the Commission's regulations.
But in 6
particular, with the TMI-related requirements in Section 50-7 34F.
Now, Section 50-34F applies in its own terms to certain 8
named plants.
Of course, there would have to be some 9
appropriate modification of those requirements.
But in 10 general, I think you can expect most of those requirements to 11 have to be met by the designer.
12 Also, the application should show a resolution of 13 unresolved safety issues, and the more important of the generic 14 safety issues.
It should include the site parameters of 15 design.
Information on appropriate emergency planning:-- in 16 particular, any feature of the design which shonld be taken 17 into consideration in planning wnich might call for different 18 planning than we generully hove, in fact, in effect right now.
19 The application chould also contain proposed tests, 20 and inspections needed to insure that the plant is built an 21 operated ?.ccording
'o design.
Finally, I thir.k it's open for 22 question whether it should also contain a demonstration or 23 compliance with some safety goal.
The policy statement on 24 advanced reactors says that the Commission will expect advanced 25 designs, and that,'in the language of that particular policy Heritage Reporting Company (202) 628-4888
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statement, includes evolutions of light-water reactors.
The 2
Commission says that such designs would be expected to meet the 3
Commission's safety goal.
I think it's open to question 4
whether that should be stated explicitly in a rule, or~ handled 5
in some other way.
That's the content of the application, I think, by 6
l 7
listing the features of the application.
You get some sense of 8
what it would mean to submit an essentially complete design.
9 Now, the rule-making procedures would of course have to 10 include written notice and comment.
Beyond that, I think we 11 are very much open to discussion.
At the moment, we are 12 leaning towards a mandatory hearing not governed by Sub-part G 13 of Part 2.
That is not a formal adjudicatory hearing.
It's 14 rather a mixed-bag hearing.
I would be before a three-judge 15 panel, as has happened in recent materials-licenses cases.
16 It would be an opportunity for parties to submit 17 questiona to the panel, and the panel then tc osk them.of 18 witnesses.
We are also seriously considering opportunities for 19 cross-examination by qualified experts.
We're not sure that 1
20 cross-oxain.i nation needs to be the kird of wild afiair that in 21 all courts of law cross-examination turns out to be.
But since 22 we're dealing with highly-technical designs, it may be 23 appropriate that the proposers of the design be open to cross-24
. examination by people who are qualified to ask appropriate 25 questions about that design.
i Heritage Reporting Company (202) 628-4888
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23 l
1 The hearing, I think, would also be governed under 2
such other procedures as the Commission would determine on the 3
basis of experience on the particular application, where l
4 appropriate.
5 Of course, ACRS review would be mandatory.
Again, a 6
finality of the familiar formula, I think, in this rule:
the 7
Commission will not back-fit design certifications unless the 8
Commission determined on the basis of new information that 9
adequate protection required modification.
The Commission 10 would be, in this case, giving up its authority under the 11 Atomic Energy Act to require something more to back-fit 12 whenever a substantial increase in protection was available.
13 We would hope that the level of safety in these designs would 14 make any thinkable advance in safety on them very 15 insubstantial.
19 Therefore, we would think that the Commission could 1
17 be correspondingly restricted in its power to back-fit.
'8 The rule provides for amendments requested by'the 19 holder of the design certificatiort.
Av the policy statement 20 said, the amendraent, if granted, would apply to all plants 21 referencing the design certification.
We are open to the 22 possibility that that sweeping application be trimmed back to, l
23 say, for instance, application for construction permits 24 submitted after the date of the amendment to the design 1
25 certification.
I think that is very much a topic for Heritage Reporting Company (202) 628-4888
l 24 l
1 discussion.
2 An applicant for a construction permit or an 3
operating license could also request variance from the design.
4 These amendments and variances would be granted as long as the 5
applications for them showed compliance with the Atomic Energy 6
Act and the Commission's regulations.
A variance granted to an 7
applicant referencing the design certification would not be 0
applied to every plant referencing that design certification.
9 The rule on design certifications also contains 10 renewal and feo provisions analogous to those for early site 11 permits.
12 Finally, I come to the last of the three licenses, 13 the so-called " combined" license.
Now, this is an odd creature 14 under the Atomic Energy Act as it stands.
We do not have a l
15 full authority to go about granting a license which pernits 16 both construction and operation.
However,I think you will see 17 that we are able to go, ar, Stu said, a long way towara 18 embodying in the rule the provision that we have asked Congress l
l 19 to enact.
20 The combination in this license is of an ordinary 21 construction permit and a, what for lack of a better term, we 22 might call a " conditional" operating license, or a testing 23 license, a license that would also permit possession of fuel.
24 The rule does not demand that all future applications 25 be fore combined licenses, but the rule will specifically state lieritage Reporting Company (202) 628-4888
4 25 1
that the Commission will give priority to such applications and 2.
moreover, applications for combined licenses which reference an l
3 early site permit and design certification.
Thus, a utility 4
could come and ask for a combined license and present its own 5
complete design and not one that has already been certified by 6
the Commission.
But that would be asking for an extended 7
review process and the review process could be cut considerably l
l 8
shorter if the application referenced already-approved' sites 9
and designs.
10 The content of the application would require an FSAR 11 and a design certification if it is submitted.
If it-is 12 referenced, the SAR could incorporate the SFAR for that design 13 certification.
The application must also contain an 14 environmental report.
Again, that environmental report could 15 incorporate the environmental report for an early site permit.
16 Proposed tecnnical spec ifications.
Detailed 17 descriptions of plans for meeting the regulations on EESEQ i
1C eriergency plans, and so on.
In other vords, we will not i
i 19 require fu.ll emergency pleus et that state, but we will ask for i
20 act.m thorough description of how the regulation is on the 21 emergency planning would be met.
l 22 Again, proposed test inspections needed o ensure that 23 the plant is built and operated according to the design.
That 24 provision is in common with the analogous provision for design 25
-- certitled designs.
Heritage Reporting Company (202) 628-4888
4 26 1
Now, I am fairly sure that there will be a provision 2
in there for state and local commitments to emergency planning 3
and execution.
Some certification from the responsible state 4
and local governments, that at least at that point in time with 5
that party in power, they believe that the site is amenable to 6
emergency planning and, moreover, that they are committed to 7
developing the plans in their final form with the applicant, 8
and to the execution of the plans, we hope, that the 9
extraordinarily remote possibility of an accident.
10 The applicant for a combined license could request 11 exemptions in the standards that would apply to that request --
12 would be those that are already set up -- 150-12.
The hearing 13 under subpart (g) would be mandatory under a combined license 14 just as it is for construction permits right now, since this is 15 a construction permit, we would have to follow the Atomic 16 Energy Act in this case and there would be a required : hearing.
17 ACRS review of the application would, of coursn, be mandatory.
18 The general Part 50 would be applicable to holders of the
(
19 combined license.
20 Now, ance the plant is nearly completed, it would 21 come time for a so-called " conversion" of this additional 22 license, this testing license, into a full-power operating 23 license.
For that there must be a separate application under 24 the Atomic Energy Act as it currently stands.
This is the 25 ghost of an application for on operating license.
It would be Heritage Reporting Company I
(202) 628-4888 1
l
j 27 1-granted as applications are granted now, that is, if the 2
findings in 55-57 can be made, then antitrust review would be 3
done by the staff before the conversion.
(:
4 Again under the Atomic Energy Act as it stands, they l
5 would have to be an opportunity for'a hearing on the 6
application for a conversion of.the conditional license to a 7
full operating license.
In this case the hearing would be held l
8 if the Commission determines that some substantial issue 9
necessary to the Commission decision was not resolved in some 10 private proceeding on the design certification or early site 11 permit.
l 12 Although this combined license would be granted 13 before construction, we would not take the period of 14 construction out of the term, the operating term, of the' 15 11 cense.
Thus, the term of the OL, which under the Act as it 16 now stands, would be ut to 40 years, would date from the 17 effectiveness of the conversion of the combined license to an 18 operating license.
19 Now, that is the end of my slight elaboration of the 20 outline which is available to you.
I am not sure, Jerry, but I 21 think at this time perhaps we wanted to provide a few minutes 22 just for questions aimed at clarifying what I have said so far.
23 A more substantive discussion, I believe would follow later in 24 the day ofter you have all had a bit more time to refer to the 25 outline and to consider what I have said.
Heritage Reporting Company (202) 628-4888
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Let us open it up to questions now, but try to keep 1
2 them limited to clarifying the things that I said.
Questions?
l 3
VOICE:
Are there copies of your outline?
4 MR. CROCKETT:
They were available out in the hall.
5 VOICE:
We have run out of those.
They will be 6
provided additional copies after the break.
7 MR. CROCKETT:
Okay.
Yes.
8 MR. SCHERER:
A.
Edward Scherer, Combustion 9
Engineering.
A clarifying comment:
you said the FSAR may 10 incorporate the FSAR for the design certification.
And then 11 you list the proposed tech specs, ECCS, EQ, fire protection, 12 proposed tests and inspection.
Is it your assumption that that 13 could be covered by the design certification rules or would it 14 have to be in addition to any design certification rule?
15 MR. CROCKETT:
I think that could be covered by the 16 design certification rule.
I suppose that particular provision 17 we outlined is aimed at the more general situation that we are 18 allowing the opportunity for people to apply fior the combined 19 license without also referencing a design certification.
In 20 such a case I think there would have to be a detailed 21 description of your plans.
22 If you are referencing your design certification, the 23 general theory behind all of this is, let us get it all out in 24 the open just as early as possible, and we would hope that 25 design certification would settle these questions.
Of course, Heritage Reporting Company (202) 628-4888 l
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29 1
they cannot settle emergency plans.
Those are going to have to 2
be site-specific.
But I think that EECS EQ fire protection 3
could be largely resolved in a design certification.
4 MR. SCHERER:
I am curious only because those are 5
normally plotted in an FSAR.
Why did you pull them out?
6 MR. CROCKETT:
Well, there really is going to have to 7
be a -- have to be more, in fact, the rule as it now stands is 8
more careful than this outline and in saying precisely what 9
elements of an FSAR have to be presented with the application 10 and which ones do not.
I do not think I have a list right here 11 that I can provide you, but it is a more limited FSAI than we 12 would expect to be submitted in the course of the ordinary 13 proceeding for an operating license right now.
So that, in 14 some cases, we might only be able to ask for a detailed 15 description in plans in order to meet these regulations rather 16 than it actually meeting the regulations.
17 Eut this is something that certainly vill have to be 18 handled carefully in the draft.
So we raay end up with some 19 superfluous -- we may have some superfluous statements at this 20 point.
21 MR. D'ZMURA:
Pete D'Zmura of DOE.
The early site 22 confirm that --
23 VOICE:
Could you speak up a bit, for the Recording 24 Secretary?
25 MR. D'ZMURA:
Pete D'Zmura, DOE.
In the write-up on Heritage Reporting Company (202) 628-4888
30 1
early site permit you indicate that ' amenability for rapid 2
evacuation is something that ought to be considered up-front 3
and I am just wondering if you mean literally, " rapid 4
evacuation," or is that a generic term for " suitable protective 5
actions in the event of an emergency," recognizing that there 6
are many who believe that rapid evacuation, or evacuation 7
itself, is not necessarily the best thing to do in many cases.
8 Sheltering is what you really want to do, and I just wonder if 9
you are talking generically here or specifically.
10 MR. CROCKETT:
Perhaps a second phrase should be 11 added to the rule.
Certainly " suitable protective action" is 12 our desired intention.
We do not mean by the phrase,
- rapid 13 evacuation," to demand evacuation every time there is an 14 emergency of that level.
That would be an extraordinary change 15 in policy in emergency planning.
We intended nothing by that 16 particular phrase.
I guess it should be read, " conditional."
17 If evacuation is the suitable protective action, then 18 the site ought to be amenable to " rapid" evacuation, or J
19
" appropriately rapid," evacuation.
But certainly we do not 20 mean to rule out actions which, in the judgment of the 21 planners, are more suitable to the circumstances.
That may 22 call for some clarifications in the draft.
23 MR. COWAN:
Bud Cowan.
You talked about the i
24 standard design certification as being a license.
In other 25 words, the procedures for the design application are rulemaking i
l Heritage Reporting Company l
(202) 628-4888 l
31 1
procedures, not license procedures.
Would you clarify that 2
rule please?
3 MR. CROCKETT:
I suspect I ought not to be taken too 4
literally when I called them " licenses," okay?
It is a " rule."
5 MR. COWAN:
You just clarified it.
A second 6
question.
Several times in here you talk about " finality" in 7
terms of "backfit."
Have you considered, or are you planning 8
to use the backfit rule standards in these various places, or 9
are you carving out a different kind of a backfit regime?
10 MR. CROCKETT:
We are carving out a different kind of 11 a backfit regime.
This is not 5109.
5108 permits three kinds 12 of backfits:
backfits to assure compliance; backfits to assure 13 adequate protection; and backfits which bring about a 14 substantial increase in protection and backfits which bring 15 about a substantial increase in protection to e plant that 16 already provides the minimum level of protection.
17 It is the latter backfit which, in this regime, would 18 be ruled out, for the reason that we would expect a substantial 19 increase in protection to be probably not even a theoretical 20 possibility.
And so we would confine the power at backfitting 21 to those occasions when adequate protection or compliances are 22 at stake.
23 MR. COWAN:
Would you still anticipate doing the same 1
24 kind of appropriate backfit or regulatory analysis?
25 MR. CROCKETT:
1 suppose we will continue doing the Heritage Reporting Company (202) 628-4888
I 32 1
kind of regulatory analyses, the value-impact analyses we have l
2 been doing since -- at least 1981 or earlier.
Those do not l
3 contain standards for decision.
I suppose also a good deal of l
4 the backfit analysis which is required under 5109 Section C, i s, 5
_just good sense.
That what are we requiring?
What is its 6
purpose?
What is the radiological impact?
Is it permanent, 7
and so on?
Those questions, I would expect, as a matter of 8
good management, would continue to be answered.
9 I suspect, thought that there would -- well, under 10 the law as it now stands, since the August 4, decision ~1n the 11 D.C.
Court of Appeals, a cost justification standard would not 12 be part of this new backfit regime.
I mean, the Commission 13 would not, therefore, look for the most expensive way of 14 putting t he backfit into effect.
Again, costs could be a 15 consideration in choosing among alternative which have the 16 same result and the Commission would do a regulatory analysis 17 and it would try to determine which one of those alternatives 18 is the most cost-effective one, but we could not turn down a 1
19 backfit on the grounds of cost in the law as it now stands.
I 20 MR. BRINKMAN:
I am Charley Brinkman, Combustion 21 Engineering.
Under design certification, you specified that j
22 you have to have an FDA when you apply.
Two questions:
do you 23 mean you have to have it when you apply, or when you apply for 24 an FDA, you can also apply for design certification?
Can you 25 do them together?
Heritage Reporting Company (202) 628-4888
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MR. CROCKETT:
As I understand it right now, this may 2
not be the best system, but the idea was that you would have an 3
FDA in hand before you applied for design certification.
But 4
as I understand that when you apply for the FDA, the staff 5
would prefer that you say you are aiming beyond to a design
/
6 certification.
Now, perhaps we need to do some thinking on 1
7 that to see whether it would make sense to apply for both 8
simultaneously.
9 MR. BRINKMAN:
And also in the way you stated it, you 10 have to have an FDA and then you said you have to have a 11 mandatory ACRS review for the design certification.
I believe 12 the regulation has already called for an ACRS review until they 13 get the design -- the FDA.
I am thinking of the second one.
14 MR. CROCKETT:
The FdA?
I think the design -- well, 15 1 guess we will have to look at that.
It depends in part on 16 how complete the FDA is.
I am thinking off the top of my head 17 here.
If there are significant safety questions left over 18 after the final design approval, then I think ACRS review of 19 those questions would be mandatory.
But I see we are going to 20 have to look at that again more carefully.
21 I mean, it is possible to come in with a design for 22 an FDA which may not be as complete as the design we are asking 23 for for the design certification.
I think that is where the 24 difficulty is.
25 MR. BRINKMAN:
But if it were complete, you would not Heritage Reporting Company (202) 628-4888 i
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34 1
want to state that there was a mandatory ACRS review?
2 MR. CROCKETT:
I am not sure it would make sense to 3
ask the ACRS to repeat itself.
4 MR. DAVIS:
George Davis from Combustion Engineering.
5 Under design certification, what did you mean by the term, 6
" complete design?"
7 MR. CROCKETT:
We are now -- I guess that is a 8
question for clarification.
I cannot put that one off, can I?
9 I may not be entirely the right person to answer that.
So let 10 me give -- back in with a lawyer's answer and then ask if 11 somebody at the table would like to bail me out on that'one.
12 I would hope that the definition of " completeness" is 13 to some extent nailed down by the requirements for the content 14 of the application.
That is quite a list of requirements.
15 Now, how much lies beyond that., I am -- how much could, 16 theoretically, lie beyond that, I am afraid I am not really 17 technically competent to say.
Perhaps --
18 MR. DAVIS:
Well, were you referring to a lot more 19
" detail," or " scope?"
20 Mh. WILSON:
Both scope and level of detail.
So in 21 terms of complete design, I believe the Commission is thinking
)
22 of a Triple S turbine generator, even out to the switchyard.
A 23 complete design.
24 MR. RUBENSTEIN:
I would also add, we are looking 25 for, you know, some sense of your -- some sense of Heritage Reporting Company (202) 628-4888
)
35 1
standardization in both your instruction practice and Q/A.
One 2
might view it as a little more than an O/L, which would be 3
custom, and because of the importance of what we were doing, 4
and the reference ability over time of the design, where one 5
might defer to the construction stage, and the test stage, some
'6 of the things that are done on custom plants I think perhaps on 7
an ad hoc basis we would look for a better detailed 8
understanding and knowledge of a system, so that would be 9
adjudicable in the rulemaking and it would stand the test of 10 time.
11 VOICE:
Well, under the standardization policy,.it 12 allows for the -- it encourages the certification'of an entire 13 plant, but allows for a major portion thereof, as in the 14 previous standardization policy.
Do you still see that?
15 MR. CROCKETT:
The rule -- we will provide for that 16 option, however, the design of that portion should be, quote, 17 complete, unquote.
18 VOICE:
I agree.
39 MR. CROCKETT:
I don't think we would disegree about 20 this, but I don't ttJ nk we should look upon completeness as 21 something that we would be requiring of you.
I think it.is in
. :2 2 everybody's interest in this case that every question which can 23 be settled at the point of application be settled.
And that 24 there be as few -- only the absolutely necessary loose strings 25 be left over.
I think that advantage should be the driving Heritage Reporting Company (202) 628-4888 e
36 1
force behind a definition of completeness.
We have spelled it l
2 out a little bit here, but we just ought to nail everything l
l 3
down you can.
l 4
VOICE:
Well, I agree with that.
5 MR. CROCKETT:
I thought you would, right.
6 Certainly, we would provide -- the text of the rules L
7 as it now stands provides for a certification of a portion of a 8
plant, but that design of that portion would have to be 9
complete.
10 MR. RUBENSTEIN:
I would expect on scope that the 11 scope would certainly address all safety systems and supporting 12 systems that deal with the safety systems as a minimum, but 13 then in developing your product you wanted to go beyond that, I 14 think there would bo some flexibility in going into some parts 15 of the balance of the plant and beyond.
16 MR. ROWDEN; I'm Mark Ruwden.
Returning for a moment 17 to the matter of emergency planning.
You used the term, 18
" certification," in reference to a sort of commitment f rorr. the 19 ntate or local governmental authority 20 VOICE:
We cannct hear.
21 MR. ROWDEN:
The front end of the process.
Have you 22 given any thought or can you share with us your thinking on 23 what would be certified and who would be required to give the l
24 certification and what the consequences would be of the failure 25 to receive one or more of the required certifications.
Heritage Reporting Company (202) 628-4888
37 1
MR. CROCKETT:
I am not sure we though far enough 2
along on this, but I can give you provisional answers to all of 3
those.
What would be certified would be the judgment by the 4
local, the responsible local governments that emergency 5
planning was a thinkable thing for that area.
Which part of 6
the local responsible governments, which office, we have not 7
spelled out in any draft.
That is clearly a matter for serious 8
consideration.
9 Second, what would happen if they went back on the 10 certification, we don't at the moment see that we have any way 11 of holding them to a commitment that they have made at one 12 point if they want to go back on that commitment.
I guess at 13 the moment we would only hope that there might be a -- that the l
14 more visible and explicit the commitment and certification 15 were, the less likely backt.raching would be et a later point.
16 But 1 am not sure that we have an legal authority to prevent a 17 backtracking later, but we are locking into that.
18 MR. TREBY:
I guess I would like to suggest at this i
19 point that maybe we hold the rest of our questione so that we 20 can hear from Mr. Varghn and there will be more opportunity to 21 ask questions at some later time.
22 MR. VAUGHN:
Thank you, very much.
I am Jim Vaughan, 23 I am the Acting Assistant Secretary for Nuclear Energy at DOE.
i 24 And I appreciate the opportunity to present DOE's views on the 25 revised standardization policy which has been recently Heritage Reporting Company (202) 628-4888 l
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1 published and to g.ive you our tloughes on the policy
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2 implementing rules that NRC pire.s to develop.
3 We understand that the rulemaking package wilf
4 address the licensing reform r(easures that have been tra t!
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5 subject of numerous l'egislative proposals in the past c. cade.
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pationakissueandNRC'kh 6
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I guess is the unique thing'I can add to this forum, to 10 indicate our etro.ng jupport for there efforts.
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I 11 I cannot stay for the whole day, bW if later in,the.
Pete D'Zmuxe,.iuho (3) 12 day there are questiscs to be esked of DOE,
't 13 is in the bcck, helped in preparing this material.
He has 14 copies availcib)v for. people t. hat want copic.s and can either s 1 15 take question that DOE might need to answer I,.;r the rocord or
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16 respond to them orally.
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17 Because 1 get to speak a 1ittle, bit about fctiqy,\\Ist i t
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2' me first reiternte out everall perspective on the need foy y,
I 19 1icensing reform. The Administration seas this as u key vcep forsupportingAd!sinistrationpolic[whichcalls, as ycu h$ve 20 l
21 probably heard many times, for enedce, stability, segurity, and
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22 strength and nuclear pw.ver contributes ar. jpportant dimen'sion s
23 to that.
Everybody ir, Ehis room knows the figures of tc djr
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24 17 percent of this count ry's elect.ricity and 19 percent is the' 25 plants that near completier or put into operation.
Bo,.
6e are A
Heritage Reporting Company (202) 628-4888 J
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faced with a serious situation of having no additional nuclear 2
generating capacity being planned, not much coal capacity 3
either for that matter.
i l
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And, so, even under the consumption under 5
conservative' projections for growth rate and electrical demand, a
6 we are going to have a shortage of many gigawatts of new e
i sy 7
capacity by the year 2000. And 1 could sit here and predict the 8
amount, but that is not german).
The point is that the picture 9
is bleak for the nuclear optiori to meet these future energy 10 needs unless we rationalize the licensing process and still 11 maintain protection of public health and safety.
And, so, that i
12 is what we are all here ahout today.
13 I submit that the issue is not t;echnology. We harri 14 got the technology to build and operate safe and reliable and l
i 15 economically.Tound nuclear power plants.
Our experience I
i 16 demonstrates this, ioreign experience todhy is demonstrating it 17 a little Dit better.
18 I am pleased that the industry, many of whom are 19 represented here today, have been continuing to improve its 20 advanced reactor designs, to apply state-of-the-art technology v
21 and to further enhance safety by including features wi,th more 22 tolerance to operator errors and some of these advanced deuigns
(
23 are almost reany.to be licensed and constructed overseas and, j
24 so, I submit that the question is not primarily technological, 25 but institutional.
lieritage Reporting Company (202) 628-4888 I
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Now, there are numerous interrelated reasons for the 2
current hiatus we are in.
And all of us could go write our
.l 3
list on the board and we would have some differences, but there n
4 would be some common factors:
construction delays, inaccurate 5
demand projections, inconsistent actions by state PUCs, 6
uncertainty in the licensing processes, poor ratings by the 7
financial community, reduced public acceptance and knowledge.
g L
8 And we cannot solve all these problems at once. But I submit 9
that the Federal Government must do its share and the state t
10 regulatory bodies also have to do their share.
11 But for the areas where we, the Government,.have 12 become part of the problem, we have got to be part of the 13 solution and we have got to do it now, not later so that 14 nuclear power can again be a viable option for new generating 15 capacity vith reasonable and predictable lead times, o
t' 16 Fundamentally, I think if we do things like we are 17 talking about here, today, we can help break the log jam and, 18 frankly, without such action, the utilities have said and I 19 think I would clearly agree with them.
It is unlikely they 20 would consider ordering a new nuclear power plant.
21 The uncertainty in the licensing process is I think 22 the key that underscores the importance of NRC's planned 23 rulemaking.
We have frequently stated in congressional L
24 testimony that the goals of licensing reform ought to be, 25 first, to continue to assure public health and safety, second, 4
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Heritage Reporting Company (202) 628-4888 9
\\-, 21__d________________..._____ )
9 i l 41 l 1 to continue to assure the effectiveness of public participation 2 and I would submit it can be more effective under the kind of 3 scenario that is proposed here rather than the current. plan 4 because you know more about what you are talking about when you 5 have that participation. And, thirdly, and most importantly, 6 to achieve stability and predictability in the process of 7 licensing regulating, constructing and operating nuclear power 8 plants. 9 We simply have to remove any Federal disincentives 10 that are there. The rulemaking does and should address the 11 following key points: early approval of standardized plant 12 designs, early approval of plant sites, and the combined 13 construction and operating license. 14 with respect to the role of standardization, we must 15 support effective rulemaking by coherent standardization 16 policy. The last revision was in '78. The new policy focuses 17 on the use of a certified reference design which is the right 18 focus and it puts more emphasis on the need to achieve improved i 19 safety in the standardized designs and it also recognizes that 20 advance reactor concepts, as well as evolutionc of existing 21 light water reactor designs, can achieve design certification 22 status. 23 We agree with and support these changes in the 24 standardization policy and, further, I believe that the l 25 coordinated DOE and industry reactor development program l Heritage Reporting Company (202) 628-4888 i
42 1 efforts that are under way are consistent with the new policy. 2 Before I give you just a brief profile of some of 3 those efforts, let me describe briefly what we would mean by 4 good standardized design. This is not going to be the perfect 5 answer to anybody's question. It is a matter we are going to 6 have to address, but we would consider that to be considered 7 for certification, a design should be developed to the point 8 that all major safety issues have been addressed and resolved 9 by the designer. 10 In addition, the design should make appropriate use 11 of state-of-the-art technology and it should have high 12 potential for economic construction and operation. 13 Now, by state-of-the-art technology, we mean that the. 14 design reflects the best efforts of competent engineers to 15 achieve a high degree of safety, reliability, operability, and 16 maintainability. All the major R&D should have been completed 17 successfully, obviously, and some parts of a standardized 18 design may reflect work that has been done much earlier and 19 that has proven its merit over time and has not been overtaken 20 by superior technology. So, in all the important respects, no 21 matter how you get there, it is state-of-the-art. 22 We believe that a certified design may encompass the 23 entire plant, except for those parts that are tailored to a 24 particular site or a particular electric power grid or that it 25 may be limited to a major segment such as the nuclear island, Heritage Reporting Company (202) 628-4888
l i l i 43 l 1 such that it -- so long as it can be established that 2 variations in the design of the balance of plant won't 3 adversely effect the overall plant reliability or safety. 4 In either case, the full definition of the interfaces 5 has to be included in the approved design. I think we would 6 also favor the idea that a standardized plant design, that is a 7 design that is going to be certified should consist of no more 8 than two basic standardized parts which would be, of course, 9 the nuclear island and the balance of plants. 10 If we take this as background, let me digress just a 11 second and then come back to the rulemaking, to outline how we 12 think the current DOE and industry reactor development programs 13 match with and are dependent upon this rulemaking process that 14 we are undergoing today. 15 I know many of you in the room are familiar with 16 these, but maybe not all. I think you know that DOE is. working 17 with several reactor vendors with EPRI and with the utility 18 industry in the development of advanced light water reactors 19 for the Nineties. And a major objective of this program has 20 been from the beginning to achieve full NRC approval of 1 21 advanced standardized LWRs through the award of FDAs and design 22 certifications. And we expect that two of the primary vehicles 23 of this will be large, roughly 1300 megawatt electrical plant 24 designs representing at least one boiling water reactor and one 25 pressurized water reactor. Heritage Reporting Company (202) 628-4888 l
0 l l l l 44 l 1 Beyond that, we are also working with the industry to j 2 develop, if the marketplace wants it, mid-sized 600 megawatt ) 3 electric advanced light water reactors which offer the prospect 4 of further simplification and innovation and design and 5 construction because of their lower power rating and we would 6 hope to be able, again, if the market wants, to have certified 7 standardized plants in the mid-size available about 1995. 8 Now, along with that work for the near term, we have 9 got substantial programs underway to develop advanced reactors 10 that will use either sodium or gas coolants. There is one 11 innovative licensing approach for one of the advanced sodium 12 coolant reactors focused on a full-scale safety test, and we 13 are pleased to note that the policy statement would provide for 1 14 such testing and we would support that. 15 The other advanced sodium coolant reactor is 16 proceeding on a little more conventional approach based upon 17 standard licensing procedures for a demonstration module. The 18 first licensed power generating facility could then be used as 19 a test facility to conduct an agreed to set of safety j 20 demonstrations to support issuance of a design cert by'the NRC 21 hopefully so that if that approach were chosen that could 22 become standard. 23 Likewise, the modular HTGR concept is an evolutionary l 24 one based on the existing broad HTGR technology. And a 25 licensing plant as already been agreed to with the NRC that Heritage Reporting Company (202) 628-4888
45 1 includes licensing methodologies specific to the MHTGR and NRC 2 review of a standard design to obtain final design approval and 3 design cert by rulemaking. 4 These activities have already benefitted from early 5 interactions with the NRC and we would look forward to 6 constructive interactions. The message here is that as.we are ' 7 setting policy and practice for the long term, we should be 8 careful to recognize the safety features of various designs of 9 plants not arbitrarily apply every single rule for a water 10 reactor that might not apply for a reactor cooled by some other 11 coolant. 12 Now, let me turn to the subject of the licensing 13 reform rulemaking, itself. The measures that have been 14 proposed as we understand them, basically address the measures 15 in NRC's proposed nuclear power plant standardization and 16 licensing Act of 1987 which, unfortunately, still sits dormant 17 on the Hill. And the measures basically relate to one-step 18 licensing, early-site approval and reference system design 19 cert. 20 We clearly and strongly support moving forward 21 rapidly with these rulemaking efforts. We would also continue 22 to support further strengthening of these approaches through 23 legislation. We should not give up. We would like to 24 specifically recommend and suggest that the regulations that 25 are being prepared on one-step licensing include two I Heritage Reporting Company (202) 628-4888
4 ~ t ) 46 1 requirements that are at least not now covered by the 2 legislative proposals and one of which, at least, if not both, 3 have been alluded to in the prior discussion. 4 First, we would recommend that a phased approval 5 procedure for construction quality assurance should be made 6 part of each construction permit and construction and operating 7 license. 8 The phased approval concept would require both the 9 license holder and NRC inspectors to approve major systems or 10 tests as they are completed rather than at the very end of 11 construction. The process would obviously have to include a 12 before-the-fact agreement between the applicant and the NRC on 13 construction verification tests and acceptance criteria. 14 General implementation of this phased approval 15 process in our view would materially assist in improving' plant 16 construction, quality assurance, and in supporting the 17 systematic timely NRC review and inspection of plant 18 construction and design verification. 19 Some of this has been done on a trial basis. It works 20 well. It has been used in building some of the more modern DOE 21 facilities. We think it is key step. 22 Secondly, as has been touched on here this morning, 23 we believe that a process to settle emergency preparedness, l 24 feasibility and participation issues before plant construction j 25 starts should be put in place. We think that such a process is ) Heritage Reporting Company I (202) 628-4888 w_____-__________
4 47 t I necessary to insure that these important issues are not left 2 unresolved until a point where substantial investment has been 3 made. 4 As an example, we would like to see NRC's 5 determinations on emergency planning incorporated in a combined 6 construction and operating license in such a way as to 7 constitute final decisions which could not be modified absent 8 significant new information. 9 Now, I know that is a tall order. I know you have 10 got to define how much you can do, but I guess my message is: 11 the maximum we can define that we can do, the better off we 12 are. 13 We obviously believe that any rule changes along 14 these lines ought to be consistent with adoption of NRC's 15 March 6, 1987 proposed rules on issuances of full power 16 licenses, which we've also supported. 17 Now the other two measures that are key to licensing 18 reform and to the use of more standard plants are the 19 provisions for early site approval and the reference system 20 design cert. 1 21 We agree with the thrust of these measures as were 22 expressed in the NRC's proposed 1987 Standardization Licensing 23 Act, and I don't have any specific suggestions to add at this 24 time. We of course, along with everybody else, look forward to 25 carefu1]y reviewing the actual rule changes as they become Heritage Reporting Company (202) 628-4888
48 1 available for comment. 2 This concludes my remarks, Mr. Chairman. I want to 3 thank you for letting me come and present the adminstration and 4 the Department of Energy's views. We stand ready to help in 5 any way we can in this process to the degree that it is 6 appropriate and helpful to do so. 7 MR. WILSON: Thank you, Mr. Vaughan. I have received 8 a request to take an extended break at this time. Is that 9 still correct? I am looking at the folks from NUMARC. About 10 how long would you like? 11 VOICE: Thirty minutes would be fine. 12 MR. WILSON: Okay. Would you like to use this room? 13 VOICE: Yes. 14 MR. WILSON: We're going to go off the record now. 15 (Whereupon a 30 minute break was taken.) 16 MR. WILSON: If you ask a question from the audience, 17 I would like you to come up to the first chair here and speak. 18 At this point we have a microphone and that should be able to 19 pick you up. Be sure and state your name before you ask the 20 question. 21 Our next speaker today is Mr. Priory. 22 MR. PRIORY: Thank you, Jerry. I understand the 23 stock market was up about two hundred points, so I stand before 24 you more of a man than I was last evening, I can assure you of 25 that. Heritage Reporting Company (202) 628-4888
49 1 (Laughter.) 2 Good morning. I am Richard Priory, and I am vice-3 president of design engineering for Duke Power Company, and I 4 am here today as Chairman of the NUMARC management and 5 resources council and standardization oversight group. I am 6 accompanied here today by a number of the members of that group 7 as well. 8 Now the study group, on the practical application of 9 standardized nuclear plants in the U.S., was established by the 10 Atomic Industrial Forum in March of 1985, with members 11 representing a very broad cross section from the industry. The 12 study group concluded its activities in November of 1986. 13 The objectives of that study were to determine the 14 practical benefits of standardizing commercial nuclear plants 15 in the U.S. and the actions that would be necessary to bring 16 standardization about as a reality. 17 The NUMARC standardization oversight group, on the 18 other hand, is responsible for endeavoring to bring about the 19 benefits of standardization and licensing reform, as delineated 20 in the AIF study report, as soon as possible for the next 21 generr. ion of nuclear power plants. 22 The study group believed, and we continue to believe, 23 that nuclear power is a crucial component of the electrical 24 power supply in the U.S., and that standardization would 25 provide a major stimulus to the revitalization of this nuclear 4 Heritage Reporting Company (202) 628-4888 l .a
50 1 option. 2 Now today with our electricity demand exceeding 3 predictions, standardization is important for the future of our 4 industry, perhaps now more than it ever ' as been, and.the time 5 for planning that future is right now. 6 We are encouraged by the initiative the Commission 7 has taken in issuing the September 15 standardization policy 8 statement, and by the constructive course which the policy 9 statement charts. 10 And in particular we welcome the Commission's strong 11 endorsement of design standardization and its recognition of 12 the multiple benefits that could be realized from l 13 standardization's full implementation. 14 We are also encouraged by the Commission's stated 15 intent to put in place a design certification, with a 16 complementary licensing regime that will promote the practical 17 achievement of standardization's goals. 18 Further, we welcome the Commission's intent to make 19 resources available on a priority basis to facilitate the 20 reference system design certification process for these 21 essentially complete designs, and for the licensing review of 22 applications referencing those certified designs. 23 Moreover, we fully support the premise inherent in 24 the Commission's standardization policy statement that the 25 objective in formulating implementing recommendations will be Heritage Reporting Company (202) 628-4888 ) l
1 1 51 1 to accomplish through the rule making process the aims of the 2 legislative licensing reform proposals, which have been 3 submitted by the NRC to the Congress earlier this year. 4 We believe, as does the Commission, that much, if not 5 all, of the provisions of the Commission's legislative proposal G can be implemented under existing statutory authority. The 7 existing statutory authority would permit establishment of: 8 one, procedures for the certification phase of standardized 9 design approvals, with the express guidance on structure and i 10 ground rules for rule making hearing process. ) 11 And two, companion procedures for early siting 12 decisions, and three, a clear and firm regulatory standard for 13 the re-review and re-litigations of issued covered by these 14 design and site approvals. 15 And also consistent with the Commission's current 16 regulations, we do believe that the Commission may combine in a 17 sing 1. license the activities of an applicant which would 18 otherwise be licensed severally. 19 We would underscore, however, that the importance of 20 other, fundamental regulatory steps which are needed to give 21 viability to the standardization program and bring it to its 22 full potential. 2' Specifically, we consider it vital that the design 24 standardization program be accompanied by the establishment of 25 practical licensing procedures for utility applicants. A Heritage Reporting Company (202) 628-4888
52 1 fundamental to any reform of the licensing process must be a 2 provision for the single stage licensing. 3 We believe it is possible to provide sufficient 4 information and criteria, when a plan is first proposed, to 5 enable the NRC to determine prior to the commencement of 6 construction whether the facility can be constructed and it can 7 be operated in conformity with the Atomic Energy Act and 8 Commission regulations. 9 This, indeed, is one of the major benefits realizable 10 from the design and site pre-approval. The opportunity for the 11 public to provide input to the process and to challenge the 12 plant clearly should be afforded when such input is meaningful. 13 Before the facility has received authorization for 14 construction, such fundamental issues as whether the basic 15 design is safe, whether the site is suitable, and other i 16 important technical and operating perimeters should not be left I 17 open to challenge until plant construction is almost complete. J 18 To do so simply introduces uncertainty and 19 unpredictability without contributing to safety. Now 20 perimeters and requirements for matters such as assurance of 21 quality of construction and emergency planning can also be 22 established before the facility is approved for construction. l 23 Inspections, test and analysis, and acceptance 24 criteria can be established at the initial stage of the 25 licensing process before the combined construction and l Heritage Reporting Company j (202) 628-4888 L -__--- ----_ -_-__________ _ _ _ _ _ J
53 1 operating license is issued, and thereafter, the NRC should 2 assure compliance with the license through its inspecting and 3 testing process utilizing a firmly managed, sign-as-you-go l 4 process. 1 5 Now when the plant is ready for operation, any 6 opportunity for hearing should be required to meet a meaningful 7 good cause standard. And further, since design site, site, and 8 related issues will have been resolved before commencement of 9 construction, any pre-operational hearing would focus on issues 10 of license compliance with construction authorization 11 requirements and commitments within a frame work of 12 inspections, tests, analyses, and acceptance criteria that have 13 been previously specified. 14 What we recommend, in short, is a licensing process ~ 15 that is akin to that proposed by the Commission in the 16 standardization legislation it submitted to Congress in 17 January, and we believe such a process to be essential if 18 standardization is to have the necessary regulatory i 19 underpinning. 20 We have noted and we fully endorse the priority which 21 the Commission has assigned to the implementation of the 1 l 22 standardization and licensing reform policy statement. In 23 keeping with this priority, we urge the NRC to proceed l l 24 expeditiously with the rule making process. J 25 There are currently three standard plant applications Heritage Reporting Company (202) 628-4888
4 54 1 before the NRC, and guidance is needed to prevent unnecessary 2 risk for these applications. We believe completion of rule 3 making in physical year 1988 is necessary, we believe it is 4 achievable, and we also believe it is in the spirit of the 5 priority this issue has been assigned by the Commission 6 themselves. 7 In closing, let me reiterate the industry's strong 8 support of the important first step taken by the NRC 9 Standardization Policy Statement. And we look forward to 10 constructively contributing to the Commission's plans for 11 implementation of the policy statement. 12 And following this workshop, the NUMARC 13 Standardization Overgroup will finalize its detailed comments 14 on the policy statement, and will submit them to the NRC prior 15 to the October 30 deadline. 16 I want to thank you for the opportunity to provide 17 the nuclear industry's perspective on this very important 18 matter, and we do firmly believe that the nation's future 19 nuclear option for generating electricity strongly depends on 20 the rules and regulations that will follow this NRC 21 Standardization Policy Statement. 22 Thank you. 23 MR. WILSON: Thank you. I would like to call on Jack 24 DeVine from EPRI. 25 MR. DEVINE: Good morning. I would like to use the l Heritage Reporting Company (202) 628-4888
4 I-55 I slide projector here. 2 My name is Jack Devine. I am the senior program 3 manager for the Advanced Light Water Reactor Program. I would 4 like to discuss with you this morning for a few minutes our 5 program with respect to its standardization implications. 6 1 recognize that a lot of you here are very familiar 7 with the ALWR program, and I will try not to bore you with a 8 commercial for the program, but certainly it has some 9 significance -- I think a great deal of significance -- with 10 respect to standardization, and I think it may be worth our 11 time to cover some of those points. 12 As we do so, I will be stating also our position with 13 respect to the importance of standardization. I don't want to 14 pull the punch there: it is fully supportive of the things 15 we've this morning. And some few comments on the 16 Standardization Policy Statement, which we have all reviewed. 17 Again, at the outset, without pulling the punch, I 18 think it is important to point out that the EPRI ALWR program 19 is simply a standardization initiative which will develop an 20 evolutionary plant concept. 21 In so stating, I really have to underscore the 22 comments of Les Rubenstein this morning in that respect. There 23 is a point of some semantics confusion, I think, as a result of 24 the words in the Standardization Policy. 25 It refers to advanced plants as some later generation Heritage Reporting Company (202) 628-4888
1 56 1 requiring prototypical testing. In a sense that is a 2 contradiction in terms, at least as we have defined them in our 3 program. Our Advanced Light Water Reactor by definition is one 4 which will not require prototypical testing, and which is fully 5 consistent and very common and parallel with the 6 standardization concept envisioned by the NRC policy. 7 (Slide.) 8 By the way, this is a rather skeletal set of slides. 9 I do have copies with me, though, and I will put them out on 10 the table after this meeting. 11 Basically, why EPRI is trying to do in this effort is 12 establish leadership to create a viable nuclear generation 13 option in this country for the next generation. In so doing, 14 we are formulating, we think, a practical and credible 15 foundation for the design of the Advanced Light Water Reactors. 16 This is not a design project. We are not creating a 17 design per se. Ilowever, the degree of detail involved 18 certainly extends to the conceptual design level, and I wil] be 19 describing the Advanced Light Water Reactor requirements 20 document, which is a very fundamental step in the develop nt 21 of the products needed to support the deliverables outlined in 22 the policy statement and the subsequent rule making. 23 (Slide.) 24 A few comments about the path that we are on in this 25 program. And again, I will try to keep this fairly concise, Heritage Reporting Company (202) 628-4888 l l
57 1 recognizing you are all pretty familiar with it. l l 2 This is a utility driven program sponsored by EPRI, 3 of course, which is a utility supported organizat, ion. It is 1 4 totally utility endorsed, but in particular we have a 19 person 1 5 utility steering committee, comprised of senior executives from / 6 a spectrum of utility companies involved in owning and 7 operating nuclear plants. 8 They are very active and energetic participants in 9 the program. This the nuclear utility industry statement of 10 what they are looking for in their next generation of reactor. 11 This is a very evolutionary program. 12 Again, consistent with the policy statement outlined 13 by the NRC and certainly with the AIF/NUMARC initiative. Our 14 concept of an advanced reactor is one which is building on 15 everything that has wsrxed so far, and not throwing out the 16 baby with the bath water. 17 We involving NSSS vendors and architect / engineers. 18 Teams involving, again, basically the spectrum of suppliers who 19 would be involved in creating a standardized reactor plant. We 20 are working with the NRC, we think, in a very constructive and 21 non-confrontation 1 environment. 22 We don't have a gun to our head for license. NRC has 23 been very interactive and cooperative so far, and we greatly 24 respect and appreciate the support we are getting from Les and 25 his team in developing our Light Water Reactor requirements Heritage Reporting Company (202) 628-4888 I I
58 l 1 documents. 2 We are trying to establish a starting point for 3 standardization, and it's a pretty big step down.the road. 4 (Slide.) 5 With respect to a starting point for standardization, 6 there are three distinct things that we are working on in this 7 program. 8 A regulatory stabilization; it's really been underway 9 since 1982, and if you look at the Standardization Policy, one 10 of those simple bullets in there is conform with existing 11 regulations. Well, we're trying to define that in very 12 specific terms: what are the existing regulations. 13 The full body of regulations, including the rules and 14 requirements as well as the guides and positions and all those 15 things that go with them. 16 We are creating a utility requirements document, 17 which is a comprehensive set of design requirements for the 18 Light Water Reactor. Emphasize comprehensive: this covers the 19 entire plant, and it covers a degree of detail which I think is 20 unprecedented in terms of a utility design criteria document or 21 a specification document fer a new plant. 22 It also includes small plant design development. 23 Somebody this morning used the term "mid-sized." They are the 24 same. We are looking at options in the 600 megawatts size l l 25 frame, and in particular exploring opportunities for further I l Heritcge Reporting Company (202) 628-4888 1
59 1 simplification and perhaps an additional increment of 2 advancement in those designs. 3 But again, the fundamental premise is that 4 prototypical development of a full plant prototype would not be 5 required for any concept laid out in the requirements document. 6 So again I think we are quite consistent with the NRC's 7 position. 8 (Slide.) 9 Quickly running through the list of what we have been 10 doing in the regulatory stabilization area. Again, picking up, 11 I think, very specifically on the points in the policy 12 statement and elaborated more fully in the discussion by NRC 13 this morning. 14 Identifying and resolving generic and unresolved 15 safety issues applicable to ALWRs on a deliverable NRALWR 16 program is a specific position statement on each of those high 17 priority generic safety issues and the unresolved issues as 18 applicable to the ALWR. 19 Our intent is for this position to be endorsed by the 20 NRC staff in their review of the requirements document, 21 ultimately to be incorporated in the final version of the 22 requirements document, which in turn will be endorsed by a 23 safety evaluation report. 24 So an established, codified base of resolutions of 25 those issues. A review of the existing body of regulatory Heritage Reporting Company (202) 628-4888
l l 60 1 requirements and guidelines in a determination of those which 2 are applicable to our requirements documents at its level of 3 detail, and a further position on compliance with those which 4 we feel we can take a compliance position. 5 There is a question here, at least in our program, 6 with respect to degree of detail. We don't feel it appropriate 7 to take positions on design details which are beyond the level 8 of detail of our investigations, but certainly those which are 9 clear and which our utility sponsors are comfortable with, we 10 will take a compliance position. 11 Identification of resolution of optimization issues. 12 This may be considered a point of departure for the policy 13 statement, but I don't think an important one. Our utility 14 sponsors have identified a certain specific areas in which they 15 feel uncomfortable or in disagreement with existing regulatory 16 positions. 17 We are identifying those specifically. We are 18 attempting to engage NRC in a resolution of those issues for 19 the ALWR program. So when the policy statement and the 20 subsequent rule making refers to compliance with regulatory 21 positions, we would certainly hope that optimization issue 22 positions covered in our effort would be in effect. 23 A definition of a policy and procedure for resolving 24 these issues, for addressing optimization issues, for having 25 NRC review the document. And early step in our program was to Heritage Reporting Company (202) 628-4888
6 l l l 61 1 get together with NRC and say, how are we going to get this 2 thing resolved? How are we going to those positions on the 3 table, get you to agree with resolutions, get you to endorse 4 our requirements document? 5 Working with NRC, we have created a basic structure 6 for accomplishing that, and that's been codified in new reg 7 1197. So there's a degree of formality in the program which we 8 think is very important. 9 Finally, interaction with the Advisory Committee on 10 reactor safeguards. We've talked to both the whole Committee 11 and the Standardization Subcommittee to keep them abreast of 12 what we're doing and I think that interaction is positive and 13 constructive. At least it has been to date. 14 (Slide)' 15 MR. DeVINE: Talking for a minute about the 16 requirements document, I said it's an extensive compilation of 17 design, construction and performance requirements, established 18 by the utility industry. And it focuses on the designer. 19 Although, because their performance requirements include 20 operational performance requirements, radways performance 21 requirements, those kinds of things, it certainly has 22 implications throughout the life of the plant, obviously in 23 construction and operation as well. It reflects utility and 24 NRC agreement on those points that I discussed a moment ago. 25 It is a starting point for subsequent detail engineering, for Heritage Reporting Company (202) 628-4888
t 4 62 1 an advanced LWR, and a basis for the development of standard 2 plant designs. l 3 (Slide) 4 MR. DeVINE: Where does that take us with respect to 5 standardization? 6 Very simply, we fully endorse Rick's comments with 7 respect to the importance of standardization as an element in 8 expanded long-term viability of nuclear power. 9 I will point again on small point of departure and 10 that is that we are looking at the requirements for an advanced 11 light water reactor, in setting specific requirements, as well 12 as objectives, performance requirements, standards, acceptance 13 criteria, whatever you want to call them, with respect to the 14 first plant, and not the nth plant of a series. 15 And that is for a very practical reason. We feel 16 certainly we are going to have to sell one plant before'we sell 17 the nth plant, and we feel that nuclear power is viable for a 18 single plant. 19 One does not have to argue that if you haven't sold 20 ten that you're not going to sell one. And for that reason 21 we've really focused on that first plant. 22 However, that is not a point of disagreement with the l ) 23 obvious benefits of a series of standardized plants. We 24 support that fully. We are simply focusing on that first plant 25 as the immediate target for which our criteria have to be met. Heritage Reporting Company (202) 628-4888 l 1
63 1 Recognize that our utility sponsors have no interest 2 or reason to support nuclear power. They want good power 3 plants. 4 We've established, if you look for example at the 5 Executive Summary or Chapter 1 of our requirements document, s 6 it says I think, in fairly specific terms, that we think there 7 are three things that our utility customers are going to need 8 before they're going to buy a nuclear power plant. 9 First, it's got to be a good power plant, plain and 10 simple. That means safe. It also means efficient, easy to 11 operate, user friendly, all those good words. 12 It has to be economically competitive with its 13 competitors and in this country we are blessed with other forms 14 of electricity generation and as nuclear industry people we 15 have to recognize that our utility customers have other options 16 available to them. So we have to be cost-competitive. 17 And thirdly, nuclear power must present, the advanced 18 light water reactor must present an element of investment 19 protection which it has not presented so far. And that means 20 predictable construction schedules, guaranteed licenseability, 21 and those sorts of things. Standardization is fully consistent 22 with every one of those objectives. Just recognizing context 23 that the people that are going to buy this plant are not trying 24 to support nuclear power, they're trying to support power 25 generation. Heritage Reporting Company (202) 628-4888
64 1 We support fully U.S. NRC's action in taking the lead 2 in creating standardization policy. We are 100 percent behind 3 that. 4 We support fully other U.S. Industry initiatives, 5 specifically the AIF/NUMARC initiative which has been very 6 effective and continues to be effective, we feel is fully 7 compatible with our ALWR program. 8 Our program is playing a key role in standardization 9 in a couple of specific areas. 10 (Slide) 11 MR. DeVINE: I think these points for the most part 12 have been covered, but to summarize, the ALWR program is 13 creating a technical basis for advanced light water reactor 14 standardization. 15 That technical basis, primarily in the form of the 16 technical requirements of the requirements document, including 17 conceptual design level of detail, applicability to the entire 18 plant, emphasis as a matter of philosophy on design 19 simplification and rugged, robust, high-margin plants, use of 20 proven technology. In effect, evolutionary plant designs, 21 compatible with the initiatives that have been discussed this l 22 morning. 23 A strong emphasis on human factors obviously is the 24 weak link in the chain from an operational standpoint that we 25 have to address to make these plants safe and acceptable to Heritage Reporting Company (202) 620-4080
65 i 1 their owners. 2 Positions endorsed by U.S. utilities. And I must 3 emphasize the importance of that, at least in our view, from 4 any standardization sense. 5 The requirements document regulatory stabilization 6 activities further provide a technical basis in the 7 regulations. 8 And in this respect I'm not talking about the rule-9 making regulatory basis that we've heard about this morning but 10 the technical basis in identifying the specific regulatory 11 requirements, resolutions of open issues, optimization issues 12 and all those kinds of things which are essential prerequisites 13 to a complete design which would be required for 14 standardization. 15 (Slide) 16 MR. DeVINE: I missed a slide. 17 The second area in which we feel that the ALWR 18 requirements program creates a basis for standardization is 19 that it involves all of the actors, all of the key players, in 20 any standardization initiative. 21 And they include the Utility Steering Committee and 22 the other utilities who support EPRI, as I've discussed. 23 They include the EPRI staff, which is involved 24 obviously in research which will support in many respects t.he 25 development of a standardized design. Heritage Reporting Company (202) 628-4888 lL___
(- f< l 's 66 1 And triple S vendors, architect engineers snd nuclear 2 consultants, in several respects. We have teams of these 3 organizations supporting us directly. Thcse same teams arq [ r 'J y 4 working on submittal of stan'dardization products f,tr / 1 o i 5 certification. t! b 6 And they are supporting the Department af, Energy ALWR~ 4-1 ft 8 7 program. So we have a great deal of synergy among 511 these l' } 8 actors. 9 We'reworkingc1pse.'yw.l,;htheDepart!entofEnergy I ( 10 as Jim Vaughn described and of course with the NHR :s Les I \\ 11 described this morning. 12 (Slide) ,e 13 MR. DeVINE: And finally, some, comments. And these 14 are not earthshaking. 15 I have to say that -- Jack Berger was looking at the 16 slide this morning and he says those are your) points of I 17 agreement. What are your points of disagreement?t 18 Frankly, we are very suppprtive of the policy, 19 statement as written. I like to te' an optimist. It's a 20 somewhat vanilla st.atement. s 21 It's not completely prescriptive or g etailed in many j 22 areas but it is the foundatJon for,a very soli.1, forward 23 thinking policy and we find it ve.:y, ver'/ co,nstructive and 24 we're very supportive of it. s 25 Some particular points that we woule provide a [ Heritage Reporting Company (202) 628-4888 1 ( h
67 1 ringing endorsement to. Certainly the certification of 2 evolutionary design says the obvious, n2 pessary first step 3 towards standardization. .4 4 We applaud NRC's application of a very high degree of ,i 5
- !:uportanco to this program by involving theicommission itself J
6 in the certification process. We think that is going to ber A 7 necessary. \\ 8 Rick talked also about the need to bring in the 9 legislative aspects as well as the rulemaking' aspects. And.. } 10 again, I know the connotation of the very high p}iority and / ? 11 visibility we are goina to have to give this eittort. ) 12 Utilization of detailed reference dasign dncluding 7 ( 13 specs, performance and acceptance and inspect' ion requirements 14 but without nameplate data. That was an important point made 15 in the AIF study report. And from a standpoint of achieving NRC 16 endorsement we don't think that NRC wants or needs or can unu ' 17 the boxcar vendor information that the plant owners need to I 18 build the plant. ~ 19 That in not necessary to establish a common basis for 20 ' Jafety certification and for nRC endorsement in licensing'of i 2-the plant and therefore we endorse the position taken on that 22 point. 23 The two point certification process FDA followed.,by 24 rulemaking. I shouldn't really refer t,that as necessarily 1 25 two stages. Certainly they shouJd be combined. But the 11ea'of s Heritage Reporting Company (202) 628-4888 t' l 1
68 1 reaching several levels of endorsement we think is solid and 2 important. 3 And the licensing criteria with respect to new plant 4 FDAs that should say, not FOAs, with the understanding as I l' 5 outlined before that compliance with current regulations 6 requires a little bit more detail and we are trying very hard 7 to be quite specific about what that means for the ALWR 8 program. 9 And we would hope that the final rulemaking would be 10 structured in a way which could embrace what we have underway. 11 That concludes my comments on the ALWR program. We 12 appreciate the time. I apologize for perhaps boring you with a 13 bit of a commercial about our program but we think it is part 14 and parcel of this whole standardization effort. 15 And I want to make absolutely sure that people here 16 understand what it is we're doing and how it fits, at least in 17 our perception, in this overall effort. 18 Thank you very much. I can take questions now or 8 19 later, if you would like. 20 MR. WILSON: Go ahead. 21 MR. DeVINE: None? Fine. Thank you very much. 22 MR. WILSON: Thank you, Jack. I would like to call 23 on Ed Scherer. 24 MR. SCHERER: I can do it from here. My name is Ed 25 Scherer, Director of Nuclear Licensing. Heritage Reporting Company (202) 628-4888
69 1 1 Very briefly, my name is Ed Scherer. I'm Director of 2 Nuclear Licensing at Combustion Engineering. l 3 Combustion Engineering participated in and concurs 4 with the statement made by Mr. Priory on behalf of the NUMARC 5 Standardization Oversight Group. 6 MR. WILSON: Thank you. Next on the agenda is Bill 7 Johnson from Westinghouse. 8 MR. SHANNON: My name is Mike Shannon. I'm the 9 Manager of Plant Licensing at Westinghouse. And Westinghouse 10 participated in and agrees with Mr. Priory's comments also. 11 We endorse his comments and will follow that up with 12 written comments later. 13 MR. WILSON: Robert Mitchell. 14 MR. MITCHELL: My name is Robert Mitchell, Bob 15 Mitchell. I'm Manager of Nuclear Products Licensing for 16 General Electric Company. 17 We have worked with the statement and with the 18 industry in helping to develop the statement. We also support 19 it. We think it's the right way to go. 20 There is a lot of good to be said for 21 standardization. 22 We will also be submitting our comments by the 23 deadline, October 30, in writing. 24 Thank you. 25 MR. WILSON: And Ed Smith? Is he here yet? Heritage Reporting Company (202) 628-4888
Q 70 1 MR. KLINE: My name is Steve Kline. Mr. Smith was .2 not able to make it. And I am Senior Licensing Engineer with 3 Bechtel in Gaithersburg. 4 I would like to read a brief statement.that one of 5 our Senior Vice Presidents, Mr. R.W. Stone, is submitting by 6 the end of this month. 7 We believe that a greater degree of standardization 8 for future nuclear power plants in the U.S. would have many 9 benefits. 10 These include less uncertainty in licensing, better 11 utilization of design resources, clear procedures for ensuring 12 an operating experience is reflected in design of new plants as 13 well as greater predictability in cost and schsdules. 14 We have presented our views on standardization in 15 essentially every forum and in a number of meetings with the 16 Commissioners and the staff. We appreciate this opportunity to 17 again express our concepts on achievable standardization for 18 the U.S. 19 The policy statement emphasizes development of 20 designs for certification which are quote " essentially complete 21 in both scope and level of detail" end quotes. 22 The issues of the scope of a standardization package 23 and the level of details for discussion over the icst 20 years, 24 and need very careful definition in any achievable 25 standardization policy. Heritage Reporting Company (202) 628-4888
71 1 We supported and worked with a AIF study group on the 2 practical application of standardized nuclear power plants and 3 its working group on design information requirements.1 4 We support the statement on the level of detail 5 developed by this group and described in the testimony to 6 Congress presented by Richard B. Priory, and believe adoption 7 of this level of detail by the NRC would be a positive step 8 towards standardization. 9 The scope of the standardized package is probably 10 next in importance in defining a practical approach for 11 standardization. 12 For regulatory purposes, it is appropriate to only 13 include safety-related features in the standard plant 14 application. 15 This would exclude administrative facilities, shops 16 and warehouses on all applications and even the turbine 17 building on the advanced plant designs where the design 18 criteria is to have no safety functions in the turbine systems 19 or building. 20 Minimizing the scope of the standardized package is 21 very important to encourage the first steps towards 22 standardization. 23 The policy statement states that the proposed NRC 24 rules will address quote "the relationship of the new 25 regulatory framework to the existing provisions of Part 50 of Heritage Reporting Company (202) 628-4888 l l
72 1 Appendices M, N and 0" unquote. 2 We believe that in order to preserve the best of the 3 current designs it is important to retain the option to 4 replicate plant designs. Likewise, the duplication approach 5 described in Appendix N and used on the SNUPPS units is an 6 extremely workable system for standardization and should be s 7 retained. 8 Proposed policy on fees indicates that the NRC fees 9 for the review of the standard plan application would be' 10 collected frem the holder, from the design certification, as 11 the design is referenced, but will be fully collected from the 12 holder of the certification at the end of a ten-year period, 13 even if the design has not been used. 14 This provides a very sub'stantial disincentive to 15 filing an application for certification. It probably should be 16 waived for the first applications. 17 We appreciate this opportunity to present our views 18 on this important subject. 19 MR. WILSON: Thank you. 20 At this point in the meeting I would like to throw it 21 open to any additional questions and comments. I would like to 22 first cf all emphasize that the purpose of today's meeting was 23 to notify you of our rulemaking program, to get your input at 24 this time and to give you an opportunity to meet the staff that 25 is working on the rulemaking so you can interact with us as we f ( Heritage Reporting Company (202) 628-4888 i L_-____-_-____________
73 1 continue to develop this program. 2 Are there any further questions of the staff? 3 MR. QUIRK: Joe Quirk of General Electric Company. 4 It was mentioned earlier this morning of a staff effort to l l 5 define the severe accident requirement. And I guess I would 6 just like to make a statement that I think it is very important 7 that that effort be done on a timely basis to support the 8 efforts that we talked about today. And also be open to 9 facilitate dialogue with the industry. And I would like a 10 comment on each of those, please. 11 MR. WILSON: I am going to ask Dr. Rosztoczy to speak 12 to that. 13 DR. ROSZTOCZY: I work in the research part of NRC. 14 We are presently in the process of developing a proposal to 15 management and the Commission on severe accident requirements. 16 In terms of scheduling, the point you have just made is our 17 goal. Our goal is try to establish this requirement on a time 18 schedule that is fully consistent with the effort that has been 19 described here today. You have seen from the slides what Les 20 Rubenstein showed in the morning, that design certification for 21 the individual designs will take place probably in 1991. Our 22 goal is to finish our work including rulemaking in 23 approximately two years. So, even if we go somewhat beyond 24 that, it would still fit into the schedule. 25 The current thinking is to enact in rule form only Heritage Reporting Company (202) 628-4888
74 1 very basic requirements for severe accidents and provide the 2 rest in terms of regulatory guides. These regulatory guides 3 will play some role in the review of the various designs and we 4 think further experience would indicate that some of the 5 information and some of the criteria that we are putting into i 6 the regulatory guides are needed in rule form, then maybe at 7 the later date we would entertain that. But right now, the 8 approach would be to have only the basic requirements in the 9 rules and the rest provided in regulatory guides. 10 MR. WILSON: Any other questions? 11 (No response.) 12 Okay. Well, I thank you all for coming out todsy and 13 we really appreciate your input and, hopefully, we will get our 14 proposed rules out for comment in the not too distant future. 15 Thank you. 16 (Whereupon, at 11:44 a.m., the meeting was 17 concluded.) 18 19 20 21 22 23 74 25 Heritage Reporting Company (202) 628-4888
75 De 1l REPOR*ER'S CERTIFICATE 2 UNITED STATES NUCLEAR REGULATORY COMMISSION 3 DOCKET NUMBER: 4 CASE TITLE: NUCLEAR POWER PLANT STANDARDIZATION WORKSHOP 5 HEARING DATE: October 20, 1987 6 LOCATION: Bethesda, Maryland 7 I hereby certify that the proceedings and evidence 8 are contained fully and accurately on the tapes and notes 9 reported by me at the hearing in the above case before the 10 United States Nuclear Regulatory Commission. 11 12 13 Date: October 20, 1987 14 a 15 50 e i AA./f i Officiay Reporter g HERITAGE REPORTING CORPORATION - gg 1220 L Street, N.W. j as ng n, D.C. 20005 19 20 21 0 23 24 l 25 HERITAGE REPORTING CORPORATION (202)628-4888 j i i
' at Rf Cg*'o, [f - j NUCLEAR REGULATORY COMMISSION UNITED STATES + y; WASHINGTON, D. C. 20555 g j \\...../ WORKSHOP AGENDA NUCLEAR POWER PLANT STANDARDI2ATION OCTOBER 20, 1987 Speaker Topic Eric 5. Beckjord, Director Introduction to Workshop Office of Nuclear Regulatory Research, NRC Jerry N. Wilson, Section Leader Sumary of Policy Statement Advanced Reactors & Standardization, RES,NRC Lester S. Rubenstein, Director Implementation of the Standardization & Non-Power Reactors, NRR, NRC Standardization Policy Stuart A. Treby, Asst. General Counsel Proposed 10 CFR 52 Rulemaking and Fuel Cycle, OGC,NRC Steven F. Crockett, OGC, NRC James W. Vaughan, Jr., Acting Asst. DOE Views on the Revised NRC Secretary for Nuclear Energy, 00E STD. Policy & Related Rulemaking Break Richard B. Priory, Chairman Standardization - Preserving NUMARC Standardization Oversight Group the Nuclear Option Jack DeVine, Sr. Program Manager Electric Power Research Institute Edward Scherer, Director Nuclear Licensing, Combustion Engineering William Johnson, Manager Nuclear Safety. Westinghouse Robert C. Mitchell General Electric Edward Smith, Asst. Chief Nuclear Engineer, Bechtel Questions and Coments
) 48 8 D S 4 E T 3 C N D D R A N FE E U OM S F F DO M E 2 S T 5 NN RO R N AN D ( E OC D A O ,A C P D D D E T P G A P I I NS N UN G ST T U T D A P SI H N L I E LE O T A U PC N GSS C I B I Z S EN N NUG H D U EE U E P D AC M QN WL I S I TO A S I EA C N T T C T R R H D N E N R N UE E FD C U I P F E I C EM E S I A M PN C AN N S ,L S M E UE N E I E G RT T E D T DC O R A O N A t T N A I s D NS T S I N T M J A T ,L C A EG T EON N Y R S I L S E S U P P Y Y TN N UI O M T E I E E C c S T T C YR L I SI A SAT E C C T T I ZS T L S U SU P I E A N A A A O F C C T T DG T E F O E P C C E N RG S R U I P L U T E E N P O L N A A M AU Y E P D F A U E E F R U C DS A E Y T EN U HN C R MD R S D U I I FA P AA N O 9 9 e9 V I E TT E R N RM R SSA P R E I O TS 7 I 8 H 9 4 8 1 3 7 7 7 9 9 R 2 9 1 7 E 1 7 1 9 7 T B T 9 1 H S 1 S M L C U U E R R G Y G T I L U P P A U U A SE A M A J l
MA R N G O T O R N I P E T N TA N M N I E A T O T L S Z I T A P E I D A T R S R E Z E T R I Y W N A D C T I l R OC I D A L P N D O A N O P R N I A N S A A T EO S T T N LI I S S E CT M G D U A M Z 8 I 7 N C NI O D C C D I 9 T R 1 N A E D SA E E OD NN G M R E E PN AO NT L V OA YT I N P E RT I RA SE M S PS TC I I VM F FD S I E E N O ON UFI DT I R T S SA NR E A C N N G C I E RT N O O N T I I E S S NN OS IS E G I I I \\ R V VN RI F Y EP O OE RS C SC X R RI UE I I E P PL C D SL AO e e 4 9 BP
ll N SN O Y T O T I t C N i A t I I A TP C L L L I P O P O F M I P E N T O K C C O t N N C Y L I E T O R A O L A L I I E Z T A T T F I E I E A R D R T D Z R O N I A A I E N D D R S IV N P S G R E I A N N A E S T T R F E D E O S U O D I N M T R T L E A E A N A A T Z H M O N T A I I T T F I S T D O E RN B A S C Y Y A O F D T I L E C DI O S F L NT U T A I S I I L V O A A E I S M K T T C t U E S F E N C N P I N t SR G SG R 8 I s 7 ST E0 I E S F K G 9 I F 1 G t AU E GS E 1 S O AC RF D AE S Y T UN U R D E SE R R E S U T R A 0,IG OH E I CT T ON U D CS S A CA Q A P NE N T NL E I M U ED DI S EP R M e e e e U S llll lll l 1,l ll ll
G N I S K A D N E M O IF I E I S L T SF E U R O I R R E M E C V A MN O OO ES I S E V T CIT I ,C LI N S EA AL O E HC G TI O O I F P T N I G A A S GT R C H E NR Y O I E I E F C F NC T T I EFC T G G R E AA R E E N N C H SE T R C I I D D N OTD N R R OR E G A A COF G G bC I N I S E E G d H N E R R O e SA D N I u NV E E TI F C C AK n OD O N N M A A I i T A A R M S tn A D T D D OL S E L I I I o EN F U U FU N N G G N R G C RA E I I S ST E S S SDE E N B E Y S S E EED D N D DS R S E S OT U D E I I I T VG V VPN A C C A OS O OOA I I M C S T RE R RRL IDA S PD P PPP MU e e o e e S l l ll
1 I FUTURE NUCLEAR POWER PLANT PROJECTS ADVANCED DESIGNS SPONSORED BY DOE: MODULAR HTGR SAFR LIQUID METAL PRISM LIQUID METAL f STANDARDIZATION LWR DESIGNS: SYSTEM 80+ (CE) ABWR (GE) APWP SP/90 (W) EPRI's ADVANCED LWR PROGRAM I
R0 0 9 9 9 W0 9 8 8 8 LD / / / / A 7 3 6 0 T ] A S 1 9 / sT I / / N IU 6 7 7 7 7 1 R ? 8 8 8 8 Pf / / / / EP 7 1 3 9 I ]0 ER 7 E 7 8 8 SR 8 / 8 ) JW / 1 / A UP 3 1 1 8 D 2 A 8 8 8 P G 8 8 / ( 1 f0 / / 0 9 I9 3 7 7 4 7 1 8 9 T - 8 8 8 8 1 SP / / / / ES 0 8 0 2 W 1 1 1 SE LUD E C H I C R S T 9 9 9 0 ) C 8 8 8 9 A W E / / / / D E LR 1 3 5 1 9 0 F 1 EW 8 9 ( 9 I V B / / / E LA 8 7 1 9 R A 7 8 8 9 9 R 8 8 8 8 / T E / / / / 1 N N 9 1 3 3 A E L G P D P AD N G A N 9 ) T E. 9 9 9 8 A S 0 8 8 8 / D N8 / / / 2 0 F O 7 6 7 1 9 ( 1 IN / 9 TE 2 0 / ST 1 9 9 US 7 7 7 8 / BY 8 8 8 8 2 MS / / / / 1 1I 9 1 2 9 ( 1 1 SEU ) S G S N I I T K O N N A O M M T I E S L D S E E 0 U I I S 0 C R A l R S N 0 E S O D S I P P E O T T S A ) l f L N R E l R D l A E E E R E F I T S S S U S C T N R N t I s s T O L c I I ( M P F D I A ( I S A N R N A E T C A E R E P I R R R D V E F D i ?
THE PROPOSED RULE ON STANDARDIZATION EARLY SITE PERMIT
- o. Authorizes LWA work (if EIS done)
Use of site for other purposes pending construction if consistent with basis of permit o Applicants must be potential Part 50 Applicants o Content of applications: must contain information on Number, type & power of facilities suitable for site Type of cooling systems for each facility Geological and meteorological characteristics of site Environmental report, as required by 51.45 & 51.50 Amenability of area to rapid evacuation o Hearing under Subpart G mandatory o ACRS review of safety issues mandatory o Fees deferred till site referenced by applicant for CP o Finality of decisions on issues in proceeding: final Except when Commission determines, on new information, that adequate protection requires modification o Duration of permit: 10 years o Renewal: Single 5-10 year renewal permitted Renewal granted if compliance with Act & 10 CFR shown Opportunity for hearing on renewal application Hearing may follow renewal if staff finds no significant changes at site
p l. 0002.0.0 . STANDARD' DESIGN CERTIFICATION o Embodies a complete design in a rule o Applicants must' hold an App. O FDA o Content of application: FSAR (but no information on, e.g., organization & current environment) / PRA, with consideration of severe accid;.its Demonstration of Compliance with Commission's regulations TMI-related requirements, 50.34(f) Resolution of USIs and important GSIs Site parameters of design Information on appropriate emergency planning Proposed tests & inspections needed to assure that plant built and operated according to design (Demonstration of compliance with a safety goal?) o Rulemaking procedures will include Written notice and comment Mandatory hearing not governed by Subpart G Before a three-judge panel Opportunity for parties to suggest questions (0pportunity for cross-examination by experts?) Such other procedures as Commission shall determine (continued)
l 0003.0.0 (Design Certification, continued) o ACPS review mandatory o Firiality: Commission will not backfit DCs Unless Commission determines, on new information, that adequate protection requires modification o Amendments: Holder of DC may request amendment Granted if complies with Act and regulations (Amendment applies to all plants referencing DC?) o Variances: Applicant may request variance from design Granteo if complies with Act and regulations o Renewal and fee provisions analogous to those for ESP 6 i l 1 L
0004.0.0 COMBINED LICENSE o CP combined with " conditional OL" (testing & fuel) o Priority given to applications referencing ESPs & DCs o Content of application: FSAR (may incorporate FSAR for DC) ER (may incorporate ER for ESP) \\ Proposed technical specifications Detailed description of plans for meeting regs on ECCS, EQ, fire protection, emergency plans Proposed tests & inspections needed to assure that plant built and operated according to design (State and local commitments to emergency planning and execution?) o Exemptions may be requested under 50.12 o Hearing under subpart G mandatory on application for CL o ACR'S review of application for CL mandatory o Part 50 generally applicable to holders of CL l o Separate application for conversion of CL to OL Granted if 50.57 findings made o Antitrust review done by staff before conversion o Opportunity for hearing at conversion to full OL Hearing held if Commission determines substantial issue necessary to Commission's decision was not resolved in prior proceeding o Term of OL dates from conversion of CL to OL
l i DOE VIEWS ON THE REVISED NRC STANDARDIZATION POLICY AND RELATED RULEMAKING I STATEMENT BY JAMES W. VAUGHAN, JR., ACTING ASSISTANT SECRETARY FOR NUCLEAR ENERGY, U.S. DEPARTMENT OF ENERGY, FOR PRESENTATION AT THE NUCLEAR REGULATORY COMMISSION STAFF WORKSHOP ON NUCLEAR POWER PLANT STANDARDIZATION, OCTOBER 20, 1987 -._m--_--_-___.___.--
i t INTRODUCTION GOOD MORNING. I AM JIM VAUGHAN, ACTING ASSISTANT SECRETARY FOR NUCLEAR ENERGY AT THE DEPARTMENT OF ENERGY (DOE). I' APPRECIATE THIS OPPORTUNITY TO PRESENT DOE'S VIEWS ON THE REVISED STANDARDIZATION POLICY RECENTLY PUBLISHED IN THE FEDERAL l REGISTER, AND TO GIVE YOU OUR THOUGHTS ON THE-POLICY-IMPLEMENTING RULES THAT NRC PLANS TO DEVELOP. WE UNDERSTAND THAT THE RULEMAKING PACKAGE WILL ADDRESS LICENSING REFORM MEASURES THAT HAVE BEEN THE SUBJECT OF NUMEROUS LEGISLATIVE PROPOSALS DURING THE PAST DECADE. THIS IS A MOST IMPORTANT NATIONAL ISSUE AFFECTING CONTINUED VIABILITY OF THE NUCLEAR POWER OPTION, AND NRC'S PLANNED ACTION WILL SURELY BE A SIGNIFICANT STEP. TAKEN TOGETHER, THE POLICY STATEMENT AND NEW RULES CAN PROVIDE MAJOR NEW DIRECTION FOR COMMERCIAL NUCLEAR ENERGY PROGRAMS IN THE UNITED STATES. THE NEED FOR A VIABLE NUCLEAR POWER OPTION LET ME FIRST REITERATE OUR OVERALL PERSPECTIVE ON THE NEED FOR LICENSING REFORM. THE REFORMED NUCLEAR REGULATORY PROCESS THAT WE SEEK IS A KEY FACTOR IN SUPPORTING THE ADMINISTRATION'S POLICY OF ENERGY STABILITY, SECURITY, AND STRENGTH. OUR NATION'S CONTINUED ECONOMIC GROWTH, WORLDWIDE COMPETITIVENESS, AND SECURITY ARE DEPENDENT ON THE CERTAIN AVAILABILITY OF SUFFICIENT ENERGY SUPPLIES. NUCLEAR POWER IS A KEY ENERGY SUPPLY SOURCE AND, AS SUCH, IT IS CRITICAL TO MAINTAINING A BALANCED AND MIXED ENERGY RESOURCE BASE. NUCLEAR POWER CONTRIBUTES AN IMPORTANT DIMENSION TO NATIONAL ENERGY SECURITY
2 AND OUR EFFORTS TO BE FREE FROM DEPENDENCE ON UNCERTAIN FOREIGN ENERGY SOURCES. TODAY, NUCLEAR POWER SUPPLIES OVER 17 PERCENT OF THE NATION'S ELECTRICITY AND THIS CONTRIBUTION WILL INCREASE TO'ABOUT 19 PERCENT BY 1995 AS PLANTS NEARING COMPLETION ARE PLACED INT 0 OPERATION. AS THESE PLANTS ARE COMPLETED, HOWEVER, WE ARE. I FACED WITH THE SERIOUS SITUATION OF HAVING NO ADDITIONAL NUCLEAR GENERATING CAPACITY BEING PLANNED. C0AL AND NUCLEAR POWER ARE TWO INDIGENOUS RESOURCES FOR ADDITIONAL ELECTRICAL GENERATION. EVEN UNDER CONSERVATIVE PROJECTIONS OF THE GROWTH RATE IN ELECTRICAL DEMAND, OUR NATION FACES A POTENTIAL SHORTAGE OF MANY GIGAWATTS OF NEW CAPACITY BY THE YEAR 2000. IN ADDITION, BY THAT TIME ABOUT 115 GIGAWATTS OF OUR EXISTING CAPACITY (OTHER THAN HYDROELECTRIC) WILL BE OVER 40 YEARS OLD. MANY OF THESE PLANTS WILL EXPERIENCE DECLINING PERFORMANCE OR FACE RETIREMENT JUST WHEN THE NEED FOR NEW SOURCES OF ELECTRICITY IS HIGHEST. C0AL AND NUCLEAR POWER WILL BE THE MOST LIKELY SOURCES FOR ADDITIONAL NEW GENERATING CAPACITY. TODAY'S REALITIES, HOWEVER, PAINT THE BLEAK PICTURE-l THAT THE NUCLEAR OPTION FOR MEETING OUR FUTURE ENERGY NEEDS CAN BE RAPIDLY FORECLOSED UNLESS WE RATIONALIZE THE LICENSING PROCESS, WHILE STILL MAINTAINING PROTECTION OF PUBLIC HEALTH AND SAFETY. WE CANNOT AFFORD TO IMPERIL OUR ENERGY SECURITY AND RELY ON ONLY ONE SOURCE OF GENERATION FOR OUR FUTURE ELECTRICAL POWER l l _--_-__a
3 NEEDS. THE NUCLEAR POWER OPTION NEEDS TO BE AVAILABLE FOR AMERICA'S FUTURE. i THE CURRENT SITUATION i WE HAVE THE TECHNOLOGY TO BUILD AND OPERATE SAFE, RELIABLE, AND ECONOMICALLY-SOUND NUCLEAR POWERPLANTS. OUR PAST EXPERIENCE DEMONSTRATES THIS. FOREIGN EXPERIENCE DEMONSTRATES THIS. SINCE 1978--THE LAST TIME AN AMERICAN UTILITY ORDERED A NUCLEAR PLANT--MORE THAN 100 NUCLEAR POWERPLANTS HAVE BEEN ORDERED BY COUNTRIES SUCH AS FRANCE, JAPAN, GERMANY, AND THE USSR. OUR NUCLEAR DESIGN INDUSTRY HAS BEEN CONTINUING TO IMPROVE ITS ADVANCED REACTOR DESIGNS TO APPLY STATE-0F-THE-ART TECHNOLOGY AND TO FURTHER ENHANCE SAFETY BY INCLUDING FEATURES WITH MORE TOLERANCE TO OPERATOR ERRORS. SOME OF THESE ADVANCED DESIGNS ARE ALMOST READY TO BE LICENSED AND CONSTRUCTED OVERSEAS. S0 THE QUESTION IS NOT PRIMARILY TECHNOLOGICAL, BUT IS INSTITUTIONAL. THERE ARE NUMEROUS, INTERRELATED REASONS FOR THE CURRENT HIATUS IN NEW UTILITY COMMITMENTS TO NUCLEAR POWER: o CONSTRUCTION DELAYS; o P00R CONSTRUCTION MANAGEMENT; o INACCURATE DEMAND PROJECTIONS; o INCONSISTENT ACTIONS BY STATE PUBLIC UTILITY COMMISSIONS; o UNCERTAINTY IN THE LICENSING PROCESS; o P00R RATINGS BY THE FINANCIAL COMMUNITY AND CAPITAL FORMATION DIFFICULTIES FOR UTILITIES; AND
4 o REDUCED PUBLIC ACCEPTANCE AND KNOWLEDGE OF NUCLEAR ENERGY. WE CANNOT S0LVE ALL OF THESE PROBLEMS AT ONCE. THE FEDERAL GOVERNMENT MUST DO ITS SHARE AND THE STATE REGULATORY BODIES l THEIR SHARE. FOR THOSE AREAS WHERE THE FEDERAL GOVERNMENT HAS BECOME PART OF THE PROBLEM, WE MUST BE PART OF THE SOLUTION. AND WE MUST DO IT NOW, S0 THAT NUCLEAR POWER WILL BE A VIABLE OPTION FOR NEW GENERATING CAPACITY WITH REASONABLE AND PREDICTABLE LEAD TIMES, AS A CHOICE IN THE MARKETPLACE. OUR ACTION CAN PROVIDE THE LEADERSHIP FOR RESOLUTION OF THE OTHER PROBLEMS. WITHOUT SUCH ACTION, IT IS UNLIKELY THAT UTILITIES WILL AGAIN CONSIDER ORDERING A NEW NUCLEAR POWERPLANT. THE NEED FOR IMPROVED LICENSING l IT IS CLEAR THAT UNCERTAINTY IN THE LICENSING PROCESS IS A KEY PROBLEM THAT UNDERSCORES THE IMPORTANCE OF NRC'S PLANNED i RULEMAKING. THE G0ALS OF LICENSING REFORM SHOULD BE: (1) TO CONTINUE TO ASSURE PUBLIC HEALTH AND SAFETY; (2) TO CONTINUE TO ASSURE THE EFFECTIVENESS OF PUBLIC PARTICIPATION; AND (3) TO ACHIEVE STABILITY AND PREDICTABILITY TO THE PROCESS OF LICENSING, REGULATING, CONSTRUCTING, AND OPERATING NUCLEAR POWERPLANTS. THE NEW RULES SHOULD REMOVE FEDERALLY CREATED DISINCENTIVES AND UNNECESSARY ROADBLOCKS TO THE DEVELOPMENT AND DEPLOYMENT OF NUCLEAR POWER. THIS ACTION WOULD ALLOW UTILITIES AGAIN TO CONSIDER THE OPTION OF NUCLEAR POWER ON ITS CLEAR l ECONOMIC AND ENVIRONMENTAL MERITS.
5 TO REALIZE THESE GOALS, THE RULEMAKING SHOULD ADDRESS THE FOLLOWING KEY POINTS: o EARLY APPROVAL OF STANDARDIZED PLANT DESIGNS; o EARLY APPROVAL 0F PLANT SITES; AND o THE COMBINED CONSTRUCTION AND OPERATING LICENSE. THE ROLE OF STANDARDIZATION EFFECTIVE RULEMAKING ON EARLY APPROVAL OF STANDARDIZED PLANT DESIGNS MUST BE SUPPORTED BY A C0HERENT STANDARDIZATION POLICY. THE STANDARDIZATION POLICY WAS LAST REVISED IN 1978. THE NEW POLICY FOCUSES ON THE USE OF A CERTIFIED REFERENCE DESIGN, RATHER THAN OFFERING FOUR, MORE OR LESS EQUALLY ACCEPTABLE APPROACHES AS IN 1978. IT PUTS MORE EMPHASIS ON THE NEED TO ACHIEVE IMPROVED SAFETY IN STANDARDIZED DESIGNS AND RECOGNIZES THAT ADVANCED REACTOR CONCEPTS, AS WELL AS EVOLUTIONS OF l EXISTING LIGHT WATER REACTOR DESIGNS, CAN ACHIEVE DESIGN CERTIFICATION STATUS. WE AGREE WITH AND SUPPORT THESE CHANGES, AND BELIEVE THAT THE C0ORDINATED DOE AND INDUSTRY REACTOR DEVELOPMENT PROGRAM EFFORTS ARE CONSISTENT WITH THE NEW POLICY. BEFORE GIVING YOU A PROFILE OF THESE EFFORTS, I WANT TO DESCRIBE BRIEFLY WHAT WE MEAN BY A GOOD STANDARDIZED DESIGN. TO BE CONSIDERED FOR CERTIFICATION, A DESIGN SHOULD BE DEVELOPED TO THE POINT THAT ALL MAJOR SAFETY ISSUES HAVE BEEN ADDRESSED AND RESOLVED BY THE DESIGNER. IN ADDITION, THE DESIGN SHOULD MAKE APPROPRIATE USE OF STATE-OF-THE-ART
a 6 TECHNOLOGY, AND IT SHOULD HAVE HIGH POTENTIAL FOR ECONOMIC CONSTRUCTION AND OPERATION. BY " STATE-0F-THE-ART" TECHNOLOGY, WE MEAN THAT THE D.ESIGN REFLECTS THE BEST EFFORTS OF COMPETENT ENGINEERS TO ACHIEVE A VERY HIGH DEGREE OF SAFETY, RELIABILITY, OPERABILITY, AND MAINTAINABILITY. ALL MAJOR RESEARCH AND DEVELOPMENT SHOULD HAVE BEEN SUCCESSFULLY COMPLETED. SOME PARTS OF A STANDARDIZED DESIGN MAY REFLECT WORK DONE MUCH EARLIER THAT HAS PROVEN ITS MERIT OVER TIME AND HAS NOT BEEN OVERTAKEN BY SUPERIOR TECHNOLOGY. IN ALL IMPORTANT RESPECTS, IT IS STILL " STATE-0F-THE-ART." WE BELIEVE THAT A CERTIFIED DESIGN MAY ENCOMPASS THE ENTIRE PLANT, EXCEPT FOR THOSE PARTS THAT ARE TAILORED TO A PARTICULAR SITE OR ELECTRIC POWER GRID, OR IT MAY BE LIMITED TO A MAJOR SEGMENT SUCH AS THE " NUCLEAR ISLAND" S0 LONG AS IT CAN BE ESTABLISHED THAT VARIATIONS IN THE DESIGN OF THE " BALANCE OF PLANT" WILL NOT ADVERSELY AFFECT OVERALL PLANT RELIABILITY OR SAFETY. IN EITHER CASE, FULL DEFINITION OF INTERFACES MUST BE INCLUDED IN THE APPROVED DESIGN. WE ALSO FAVOR THE IDEA THAT A STANDARDIZED PLANT DESIGN--THAT IS, A DESIGN THAT IS TO BE CERTIFIED--SHOULD CONSIST OF NO MORE THAN TWO STANDARDIZED PARTS, (I.E., THE " NUCLEAR ISLAND" AND THE " BALANCE OF PLANT.").
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7 DOE'S REACTOR DEVELOPMENT PROGRAM t WITHTHESETHOUGHTSASBACKGROUN0,LETMEOUTLINE'ObRREACTOR DEVELOPMENT PROGRAMS. I KNOW THAT MANY NRC STAFF ARE ALREADY FAMILIAR WITH THESE PROGRAMS. y DOE IS WORKING CLOSELY WITH SEVERAL REACTOR VENDORS, WITH THE ELECTRIC POWER RESEARCH INSTITUTE, AND THE ELECTRIC UTILITY INDUSTRY IN THE DEVELOPMENT OF ADVANCED LIGHT WATER RIHCTORS FOR THE 1990'S. A MAJOR OBJECTIVE OF THIS EFFORT IS TO ACHIEVE FULL NRC APPROVAL 0F ADVANCED, STANDARDIZED LWR'S THROUGH THE AWARD OF FINAL DESIGN APPROVALS AND DESIGN CERTIFICATIONS. THE3 i PRIMARY VEHICLES FOR THIS WILL BE TWO LARGE (APPROXIMATELY 1300 MWE) PLANT DESIGNS, A BOILING WATER REACTOR AND A PRESSURIZED WATER REACTOR. WEAREALSOWORKINGWITHTHEINDUSTRYTODEVELOP-M10dZE (600 MWE) ADVANCED LIGHT WATER REACTOR DESIGNS. ;THE MIDSIZE Q CONCEPTS OFFER THE PROSPECT OF FURTHER SIMPLIFICATION AND INNOVATION IN DESIGN AND CONSTRUCTION BY VIRTUE GF THEIR LOWER POWER RATING. OUR G0AL IS TO HAVE CERTIFIED STANDARDIZED MIDSIZE PLANTS AVAILABLE BY ABOUT 1995. a 4 q ALONG WITH THE WORK ON ADVANCED LIGHT WATER REACTORS, WE HAVE SUBSTANTIAL PROGRAMS UNDERWAY TO DEVELOP #DVANCED REACTORS THAT WILL USE S0DIUM AND GAS C00LANTS. AN INNOVATIVE LICENSING APPROACH FOR ONE OF THE ADVANCED S0DIUM COOLED REACTORS IS FOCUSED ON A FULL-SCALE SAFETY TEST. WE NOTE THAT THE REVISED,, POLICY STATEMENT PROVIDES FOR SUCH TESTING AND SUPPORT THIS PROVISION.
1 8 t l E THE OTHER ADVANCED S0DIUM COOLED REACTOR IS PROCEEDING ~DH A MORE r0NVENTIONAL APPROACH BASED UPON. STANDARD LICENSING + PROCEUURES FOR A DEMONSTRATION. MODULE. THIS FIRS 7'(LICENSED) 3 v POWER GENERATING FACILITY WOULD THEN BE USED AS 'A TEST FACILITY. TO CONDUCT AN AGREED-T0 SET OF SAFETY DEMONSTRATIONS TO SUPPORT ISSUANCE OF A DESIGN CERTIFICATION BY THE NRC. THE MODULAR HIGH TEMPERATURE GAS-COOLED' REACTOR (MK?GR) IS AN EVOLUTIONARY CONCEPT DASED UPON THE EXISTING BROAD HTGR TECHNOLOGY. A LICENSING PLAN HAR BEEN AGREED TO WITH NRC THAT INCLUDES THE DEVELOPMENT OF LICENSING METHODOLOGY SPECIFIC TO THE MHIGR AND NRC REVIEW 0F A' STANDARD MHTGR TO OBTAIN FINAL j DESIGN APPROVAL AND DESIGN CERTIFICAT' ION BY RULEMAKING. COMMITMENTTOTHECONSTRUCTIONAhDOPERATIONOFAFIRSTPLANT WOULDBEPURSUEDBY.,THEVENDOR$ANDUTILITIES. THESE DESIGN ACTIVITIES HAhE AtkEADY DENEFITTED FROM EARLY INTERACTIONS WITH THE NRC.'\\ WE LOOK FORWARD TO CONTINUED CONSTRUCTIVE INTERACTION WITH THE NRC AS OUR PROGRAMS MOVE FORWARD. \\ RULEMAKING FOR LICENSING REFORM ^ NOW TO THE SUBJECT OF THE LICENSING REFORM RULEMAKING. THE FEDERAL REGISTER ANN 0UNCEMENT STATES MAT THE COMMISSION IS DEVELOPING PROPOSED REGULATIONS TO ADDRESS THE LEGISLATIVE MEASURES CONTAINED IN THE PROPOSED NUCLEAR POWER PLANT g , STANDARDIZATION AND LICENSING ACT OF 1987. 1HESE MEASURES RELATE TO ONE-STEP LICENSING, EARLY SITE APPROVAL, AND =
9 REFERENCE SYSTEM DESIGN CERTIFICATION. WE STRONGLY SUPPORT F THESE RULEMAKING EFFORTS AND WOULD ALSO CONTINUE TO SUPPORT b' FURTHER STRENGTHENING 0F THESE APPROACHES THROUGH LEGISLATION. y WE RECOMMEND THAT THE REGULATIONS ON ONE-STEP LICENSING INCLUDE TWO REQUIREMENTS THAT ARE NOT NOW COVERED IN THE NRC y' LEGISLATIVE PROPOSALS THAT HAVE BEEN PREVIOUSLY SUBMITTED TO CONGRESS. FIRST, A PHASED-APPROVAL PROCEDURE FOR CONSTRUCTION QUALITY ASSURANCE SHOULD BE MADE PART OF EACH CONSTRUCTION PERMIT AND CONSTRUCTION AND OPERATING LICENSE. THE PHASED-APPROVAL CONCEPT WOULD REQUIRE BOTH THE LICENSE HOLDER AND NRC INSPECTORS TO APPROVE MAJOR SYSTEMS OR TESTS AS THEY ARE COMPLETED RATHER THAN AT THE END OF CONSTRUCTION. THE PROCESS WOULD INCLUDE BEFORE-THE-FACT AGREEMENT BETWEEN THE APPLICANT l AND THE NRC ON CONSTRUCTION VERIFICATION TESTS AND ACCEPTANCE CRITERIA. GENERAL IMPLEMENTATION OF THE PHASED-APPROVAL 3 ?
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PROCESS WOULD MATERIALLY ASSIST IN IMPROVING PLANT CONSTRUCTION 1 ^ y QUALITY ASSURANCE AND IN SUPPORTING THE SYSTEMATIC, TIMELY NRC -( REVIEW AND INSPECTION OF PLANT CONSTRUCTION AND DESIGN VERIFICATION. SECOND, A PROCESS TO SETTLE EMERGENCY PREPAREDNESS FEASIBILITY w AND PARTICIPATION ISSUES BEFORE PLANT CONSTRUCTION STARTS \\ SHOUi.D BE PUT IN PLACE. WE BELIEVE THAT SUCH A PROCESS IS f NECESSARY TO ENSURE THAT THESE IMPORTANT ISSUES ARE NOT LEFT 'l UNRESOLVED UNTIL A POINT WHERE SUBSTANTIAL INVESTMENT HAS BEEN i MADE. AS AN EXAMPLE, NRC'S DETERMINATIONS ON EMERGENCY j
10 PLANNING COULD BE INCORPORATED IN A COMBINED CONSTRUCTION AND OPERATING LICENSE IN SUCH A WAY AS TO CONSTITUTE FINAL DECISIONS WHICH COULD NOT BE MODIFIED ABSENT SIGNIFICANT NEW INFORMATION. WE BELIEVE RULE CHANGES ALONG THESE LINES WOULD BE CONSISTENT WITH AD0PTION OF NRC'S MARCH 6, 1987, PROPOSED RULE ON ISSUANCE OF FULL POWER OPERATING LICENSES, WHICH WE l SUPPORT. I THE OTHER TWO MEASURES KEY TO LICENSING REFORM AND USE OF MORE STANDARD PLANTS ARE EARLY SITE APPROVAL AND REFERENCE SYSTEM DESIGN CERTIFICATION. DOE AGREES WITH THE THRUST OF THESE MEASURES AS EXPRESSED IN NRC'S PROPOSED 1987 STANDARDIZATION AND LICENSING ACT, AND WE HAVE NO CHANGES TO RECOMMEND AT THIS TIME. WE WILL, OF COURSE, CAREFULLY REVIEW THE ACTUAL RULE CHANGES WHEN THEY BECOME AVAILABLE FOR COMMENT. THIS CONCLUDES MY REMARKS. AGAIN, THANK YOU FOR THIS OPPORTUNITY TO PRESENT OUR VIEWS ON THESE IMPORTANT MATTERS. THE DEPARTMENT OF ENERGY STANDS READY TO ASSIST IN ANY APPROPRIATE MANNER AS NRC MOVES FORWARD ON RULEMAKING TO IMPROVE LICENSING AND STANDARDIZATION POLICY FOR NUCLEAR POWERPLANTS.
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