ML23159A073

PR-050 - 50FR11882 - Proposed Policy for Regulation of Advance Nuclear Power Plants

ML23159A073
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Issue date:	03/26/1985
From:	NRC/SECY
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PR-050, 50FR11882
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KEYWORD: ADAMS Template: SECY-067 03/26/1985 PR-050 - 50FR11882 - PROPOSED POLICY FOR REGULATION OF ADVANCE NUCLEAR POWER PLANTS PR-050 50FR11882 RULEMAKING COMMENTS Document Sensitivity: Non-sensitive - SUNSI Review Complete

DOCKET FILE INVENTORY Document Docket No. Date 01 undocketed 02 04/18/85 03 04/30/85 04 05/24/85 05 05/24/85 06 05/24/85 07 05/28/85 08 05/28/85 09 05/28/85 10 05/28/85 11 05/28/85 12 05/28/85 13 05/28/85 14 05/28/85 15 05/29/85 16 05/30/85 17 05/30/85 18 05/30/85 19 06/03/85 Docket No. PR-50 ( 50 FR 11882) In the Matter of PROPOSED POLICY FOR REGULATION OF ADVANCE NUCLEAR POWER PLANTS VOLUME 1

• Date of Title or Document Descri~tion of Document 03/21/85 Federal Register Notice - Proposed Policy statement (published 03/26/85) 04/15/85 Comments Professional Analysis, Inc.

(Phung) (1) 04/22/85 Comments EG&G Idaho, Inc. (Zane) (2) 05/23/85 Comments Electric Power Research Institute (Taylor) (3) 05/23/85 Comments Yankee Atomic Electric Company (Edwards) ( 4) 05/24/85 Comments Department of Energy (Vaughan) (5) 05/24/85 Comments Public Service Company of Colorado (Brey) (6) 05/24/85 Comments Oak Ridge National Laboratory (Postma) ( 7) 05/24/85 Comments GA Technologies, Inc. (Northup) (8) 05/24/85 Comments Gas-Cooled Reactor Associates (Mears) (9) 05/22/85 Comments C-E Power Systems (Scherer) ( 10) 05/24/85 Comments Stone & Webster Engineering Corporation (Bradbury) (11) 05/17/85 Comments San Diego Gas & Electric (Bernath) (12) 05/16/85 Comments International Energy Associates Limited (Young) (13) 05/24/85 Comments Ecology/Alert (Nemethy) (14) 05/24/85 Comments General Electric Company (Sherwood) (15) 05/28/85 Comments Duke Power Company (Tucker) (16) 05/24/85 Comments Massachusetts Institute of Technology (Golay/Lanning/Lidsky) (17) 05/30/85 Comments Westinghouse Electric Corporation (Rahe) (18) /

20 21 PR-50 (50 FR 11882) 06/04/85 06/17 /85 05/28/85 06/13/85 Comments GPU Nuclear Corporation (Thorpe) (19) Comments Bechtel Power Corporation +/-(Schmitz) (20)

Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Bechtel Power Corporation Engineers-Constructors Fifty Beale Street San Francisco, California Ma il Address: P.O. Box 3965, San Francisco, CA 94 11 9 June 13, 1985 DOCKETED USNRC '85 JUN 17 All :OO Attention: Docketing and Service Branch OFFICE OF' SE.CR!: 7Aii, DOCKETING & SERViCF BRANCH

Subject:

Proposed Policy for Regulation of Advanced Nuclear Power Plants Federal Register Notice Volume 50, Number 58, March 26, 1985. Gentlemen: This letter provides Bechtel's comments on the Nuclear Regulatory Commission's proposed policy statement for the regulation of advanced nuclear power plants. Bechtel has been involved in the design of nuclear plants for many years. We have had major responsibilities on a number of light water reactor projects as well as many pioneering projects including the Vallecitos Boiling Water Reactor, Peach Bottom Unit l and the Fast Flux Test Facility. We are currently involved in a number of programs for advanced light water reactors, gas cooled and liquid metal cooled reactors. We believe that a policy statement is needed, primarily to clarify the extent to which different reactor systems must comply with the existing body of criteria and regulations which have been developed for light water reactors. We believe that many of the reactor systems being developed today are sufficiently different that new criteria and regulations will be necessary. Our response to the specific questions in the Federal Register Notice is given in the attachment. In general, we encourage the development of much less prescriptive regulations than is now the case, and more reliance on tests and actual demonstration of performance rather than on analysis. 5026 We believe that it is important that the Commission's final policy statement clarify the relationship of the regulations for advanced reactors to the existing regulations for light water reactors. The improvements and simplifications proposed in regulations for these different reactor systems would be equally beneficial for light water reactors. We believe that current

I u s. NL ** AR LATORY COM MISSION DO' , I' ~ JCH o. . r <Y r-1

r Proposed Policy for Regulation of Advanced Nuclear Power Plants June 13, 1985 Page two Bechtel Power Corporation designs of light water reactors are adequately safe and that major increases in safety margins for future plants are not justified. The intent of the designers of most of the newer systems proposed is to attain a comparable level of safety in a simpler, more demonstrabable or more cost effective manner rather than to provide greater margins of safety. A number of NRC administrative procedures changes on issues such as backfitting need to be changed and demonstrated on current plants before new plants of either current or advanced designs can be considered. Any policy statement on the regulation of advanced reactors is incomplete without discussing these points. We appreciate the opportunity to comment on this proposed policy statement and would be pleased to meet with you or to provide additional details on the points made. RPS: lm Encl. Sincerely yours, ~/ ~ Chief Nuclear Engineer

I Question l Question 2 Question 3 Question 4 Question 5 Question 6 BECHTEL COMMENTS ON PROPOSED POLICY FOR REGULATION OF ADVANCED NUCLEAR POWER PLANTS Should the NRC's approach be revised to be less prescriptive? We believe that it is desirable to have much less prescriptive regulations for all types of reactors including light water reactors than is now the case. This is particularly true for advanced reactors where the design is very incomplete. Verification of performance criteria should be less difficult that verification of generalized design criteria. Should regulations for advanced reactors require more inherent safety margins? The margins required by the present regulations have been widely debated and used. There is no reason to apply stricter criteria to new or different designs. In any case, the term "inherent safety margins" needs definition in order to be useful. For example, does it mean margin to meltdown, margins in load combinations or margin in failure criteria? Should licensing regulations mandate simplified designs? It would be desirable for regulations to allow and encourage simplification, compared to the existing regulations.

However, it would be difficult to mandate" simplification without becoming very prescriptive in the approach.

Should regulations for advanced reactors be based on existing regulations? A new set of design criteria should be established for each new reactor type as the design is developed and experience is , gained. This would be desirable to take maximum advantage of the unique features of a particular concept as well as to avoid undesirable carryover from the existing regulations. Should primary safety functions be concentrated in a few systems? We believe that it is premature and inappropriate for the Commission to favor any particular design approach for advanced reactors based on the number of safety systems

• What degree of proof would be sufficient for the NRC on advanced reactors?

Demonstration of safety adequacy needs to be considered in the context of the review of a specific design and developmental plan. We do not believe that it is useful to generalize on the degree of proof that is required.

Nuclear Mr. Samuel J. Chilk Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, DC 20555

Dear Mr. Chilk:

May 28, 1985

Subject:

Request for Comments on NRC Proposed Policy for Regulations of Advance Nuclear Power Plants GPU Nuclear Corporation 100 Interpace Parkway Parsippany, New Jersey 07054-1149 (201 ) 263-6500 TELEX 1 36-482 Writer's Direct Dial Number: DOCKETED USNRf' 985 JUN -4 A10 :42 OFF ICE OF SE.CRt 1.-\\R *, DOCKETING & SERVlr:f. BRANCH The staff of GPU Nuclear Corporation (GPUN) herewith submits comments on the subject proposed policy. Comments were requested in a March 26, 1985 Federal Register notice (50 FR 11882). As a general comment, we believe this policy is a good attempt at getting a head start on the regulation of a new generation of nuclear power plants. However, we believe that the NRC is continuing to be too prescriptive in these new regulations. The Federal Register notice also contained six specific questions; our answers to those are contained in the enclosure. RPJ:dls:1886f Enclosure Y;fk-~ J. R. Thorpe Director Licensing & Regulatory Affairs ~-1 b *.. -JUN _4 1985 ... J Clln,1, *** ~---~.-. h~1'il\\~ GPU Nuclear Corporation is a subsidiary of General Public Ut1l 1t1es Corporation f

U, S. NUCLEAR REGULATORY COM '111SSION (J I _ rJ:- "f ,t.. f (, ( tJ 1J,

Enclosure

1.

Regulatory approach should be less prescriptive and more design objective oriented. Design objective should apply to safety goals, safety approach and safety margins.

2.

There is no clear cut answer to item 2. As in question l, clear objectives would produce designs that would handle the problem identified in question 2.

3.

Mandating 11simplified 11 designs are unnecessary. Designs will come out simple, consistent with the design objectives, if the objectives are clearly stated.

4.

We would strongly recommend for applying current experience, modified to be less prescriptive and more criteria-oriented, rather than a case by case basis.

5.

Again an illustration of being prescriptive. If a good job is done on criteria and goals, then the designs will come out adequate to meet these criteria.

6.

We would recommend a prototype approach on a totally new reactor concept.

I Box 355 Westinghouse Electric Corporation Water Reactor Divisions Pittsburgh Pennsylvania 15230-0355 Mr. John C. Hoyle Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTENTION: Docketing and Service Branch NS-NRC-3037 DOCKETED ~if ~o. 1905

• as JUN -3 All :41 GFFIC~ Or StCRt:.-Af-:

OOC.{ETING & SER VIC:f. BRANCH

SUBJECT:

Proposed Policy for Regulation of Advance Nuclear Power Plants, 50 Fed. Reg. 11882, March 26, 1985

Dear Mr. Hoyle:

In response to the Commission's request for comments on the subject proposed policy statement, Westinghouse is providing the attachment 11 Comments on Proposed Policy Statement 11 for consideration. We appreciate having the opportunity to comment on this important matter and are available to discuss our comments in more detail if you should so desire. /jag Attachment Very truly yours, I E. P. Rahe,

r.

Manager Nuclear Safety Department

ATTACHMENT TO NS-NRC-3037 Comments on Proposed Policy Statement The Proposed Policy for Regulation of Advance Nuclear Power Plants (Fed. Reg. 11882, March 26, 1985) emphasizes the Commission's position of maintaining an improved licensing and regulatory climate for advanced power plant designs. The policy statement should recognize that future designs do not necessarily require significantly different features to be viable and licensable. There should be an increased emphasis on design features that address the operability and maintainabilty of a plant utilizing past experience and proven technology in this area. The following comments pertain to the general characteristics noted to be desirable by the Commission in the reference policy statement.

1.

2.

We favor early interaction and NRC review of new designs. The NRG/Westinghouse interaction on our Westinghouse Advanced PWR RESAR-SP/90 is an example of a process in practice. For NRC and public involvement on any new design, it is necessary to have in place a Preliminary Design Approval <PDA> option. This option requires the commitment by all parties to effectively follow the process established. This policy must recognize and be consistent with the standardization policy concepts that exist and are being proposed. The policy statement leans too heavily on the premise that future designs must have significantly different features and technology to be safe and licensable. Current plant designs already have a proven record of inherent safety. Future developments should be extrapolations of our existing experience base and should be focused on enhancing reliability, maintainability, and operability as they relate to plant safety, therefore the policy statement should place more emphasis on these aspects of plant design. While the policy statement contains the seed of encouraging design innovation based on proven technology, this concept should be reemphasized throughout.

3.

We strongly question the USNRC's stated willingness in this policy statement to review designs proposed by foreign vendors. The Atomic Energy Act of 1954, as amended, provides no extraterritorial jurisdiction to the NRC in the review of designs which may neither be manufactured or licensed in the United States. Improper exercise of USNRC jurisdiction could give rise to legal challenges.

4.

The policy statement indicates that the review of advanced reactors would be done by a new staff group. Since advanced designs do not have to be significantly different and previous staff review experience is invaluable, a separate multi-discipline staff group is not recommended. The advanced reactors group should rely on the expertise that exists in the current staff technical organization most familiar with the technology on which the specific design is based.

5.

In order to ensure a design is commercially viable and has a sincere backing for use as a utilization facility, there should be a requirement that private U.S. domestic funds have been previously invested in any design to be reviewed, and that the design has a market interest, viable operating cost, overall cost effectiveness, and a demonstrated evidence of workability. These criteria would ensure that the staff would not be subject to academic review activities and therefore provide focus on those concepts with demonstrated likelihood of commercialization. In response to the specific questions at the end of the policy statement the following comments are made.

1.

2.

Westinghouse believes that the place for prescriptive design objectives and performance requirements belongs in industry codes and standards and commitments by the licensee; therefore, a reduction in the number of prescriptive regulations is desirable. The concept and practice of performance standards currently works in several areas. The key factor is reaching agreement on what are the important parameters and critical limits (e.g. Appendix Kand Safety Goal) which then may be addressed in the design for any reactor plant design with the support of industry codes and standards for implementation. In order to reduce the conflicts that arise between detailed regulatory guidance, a designer and operator should be able to trade off design or operating margins related to regulatory criteria to achieve a safety balance between design and operation. The question of providing more safety margins for advanced reactors does not recognize the inherent safety margins that exists and are adequate in the current designs. The record shows that current designs can and have performed in off normal and beyond the design bases conditions without injury to plant operators and the public. If systems are to be designed for events beyond the "design bases" then that becomes in effect a new set of requirements which will not add to the simplification of advanced plants and will not improve the licensing climate.

3.

Simplifying systems and reducing operator actions may be desirable objectives for the designer and operator of a reactor plant; however it is not appropriate nor warrented that this be mandated by the NRC. Simplified systems may mean fewer components or more passive systems; however the Commission must recognize that the existing safety system reliability is adequate and and demonstrated to be acceptable. Studies to determine the application of passive systems should be the responsibility of the designer. Reducing the number of operator actions would require more automatic functiohs thereby increasing complexity. Such a system would also require a prediction of all possible occurrences and transients that may be encountered. Removing

the operator from performing tasks and making judgements is not a criteria to be regulated since there must be a balance between reducing operator action and the degree of design complexity. In addtion the degree to which operator actions should be reduced depends on a detailed design specific human factors assessment of operator performance in the man machine interface. As such it would not be appropriate or desirable for generic licensing regulation to mandate the fewest required operator actions *

4.

Westinghouse does not believe that a new set of general

5.

6.

design criteria for advanced LWR designs is consistent with stability and certainity in the licensing process. The General Design Criteria have survived intact with many designs. These non-prescriptive criteria have remained remarkably durable. The suggestion of having a few large systems rather than multiple subsystems is a very complex question that is dependent on many variables within the system function, success criteria and component size required. Engineering evaluations would still be required including cost/benefit balancing. For example reliabilty of a system can be reduced by incorporating large components into the design,(e.g. large versus small diesel generators). However multiple subsystems can increase the overall safety

• of the plant since they allow ways of bypassing failures and accomplishing a mission.

In other words multiple systems give recovery options and defense in depth for unknown and beyond the design bases sequences and events. The Commission should not regulate or mandate specific design features for a plant since the designer and operator must balance both the operations and safety of the design. The question on whether the technology is proven or should be demonstrated has already been considered in the regulations, i.e. 10CFR50.34(a) (8). In this regulation if a concern is identified and a research and development program is required to show design adequacy then a program must be established and safety questions resolved prior to the end of construction. The degree of uncertainty and specific concerns to resolve a safety question would therefore dictate the need for prototype testing.

DEPARTMENT OF NUCLEAR ENGINEERING MASSACHUSETTS INSTITUTE OF TECHNOLOGY 77 Massachusetts A venue Room: 38-174 Hon. Nunzio J. Palladino

Chairman, May 24, 1985 U.S. Nuclear Regulatory Commission Washington, D.C.

20555 and Secretary of the Commission Attn: Docketing and Service Branch Cambridge, Massachusetts 02139 HAY 30 ...,, I \\ r ~ 1,

SUBJECT:

Proposed Policy for Regulation of Advanced Nuclear Power Reactors by the Nuclear Regulatory Commission under 10 CFR Part 50

Dear Sirs:

(617)253-3808 We agree that it is desirable for the NRC to establish an Advanced Reactor Group, in the office of Nuclear Reactor Regulation, that will "prepare a plan for the development of regulatory er i ter ia for licensing proposed advanced reactors... " as des er i bed on page 1 0 of the subject Policy Statement. We believe that the policy statement establishing the Advanced Reactor

• Group should be issued as soon as possible, to assure potential vendors and users that a stable regulatory environment will be provided.

In addition to the establishment of the Advanced Reactor Group, the policy statement should call for establishment of safety goals, independent of reactor type, that will be used for guidance of the Advanced Reactor Group in their development of regulatory criteria. Because it is important that regulation for Advanced Reactors be visibly and firmly protected from the historical causes of instabilities in power reactor regulation, we believe the following framework should be instituted:

1.

2.

Primary Safety Responsibility must be placed in the hands of the owner-operator. In order to assure the NRC that such reponsibility is met, the owner-operator must: (cont'd) JUI' 3 by c! rd. ; ~............. -.

.oo... l\\ OF I I u s. NucL

Page Two Hon. N.J. Palladino May 24, 1985

a.

prove that the design and operation can meet the safety goals;

b.

prove that the plant is constructed with the quality re-quired to meet the design safety goals;

c.

prove that the operation of the reactor is within the quality required to meet the operational safety goals. The current regulatory policy has often been unsatisfactory with respect to the first principle; the prescriptive method of regulation and backf i tting is a disincentive to responsible safety. The owner-operator often waits for an NRC mandate, even when fully aware Of the need to improve a system, because independent action, no matter how rational, is liable to be reversed. Thus, the owner-operator, who is most closely related to the need and who possesses plant-specific understanding, is left feeling less than fully responsible for safety. In order to move the safety responsibility back to the owner-operator, the NRC must set quantitative safety goals. Proof that the design meets the goals must be provided to the NRC through* mutually agreed upon methods of analysis and testing. We believe that the analysis should, insofar as possible, follow the Integrated Approach recently developed for reactor system design. Proof that the plant is constructed and operated within the quality requi~ements established to meet the safety goals must be provided through quality assurance

plans, technical specifications, and audits throughout construction and operation.

Demonstration testing and type licensing, similar to the Aircraft Airworthiness Certification is a useful precedent in some cases for relating tests to safety goals. Further discussion of these concepts is given in Ref. 1. The Advanced Reactor regulation policy provides the opportunity to make major advancements in clarification of safety responsibility and provision of regulatory stability. We strongly recommend that this opportunity be recognized and grasped with a firm, highly-visible commitment. Sincerely, DA ANNING : ~f.!c~~ Nuclear Engineering ~ / LML/cal

1.

"National Strategies for Nuclear Power Development," Richard Lester, et al, MITNPI PA-002, March 1985.

HAL B. TUCKER VJOE P R ESIDENT NUCLEAR PRODUCTION May 28, 1985 Secretary of the Commission P.O. B OX 3318 9 CHARLOTTE, N,G, 2 8 242 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Docketing and Services Branch

Subject:

Federal Register, Proposed Policy Statement, 10 CFR Part 50, Proposed Policy for Regulation of Advance Nuclear Power Plants

Dear Sir:

TELEPHONE (704) 3 73 -41ml DOGKETED USNRC -S5 HAY 30 All :56 GFFiCE Oi-Sc.Cr!:.. 7.~;- 00CKETING & SERVICL BRANCH The NRC requested in a Federal Register Notice dated March 26, 1985, (Vol. 50, No. 58, FR 11882-11884), comments on the subject policy statement and the six questions asked by the Commission. In response, Duke Power Company offers the following for consideration. General Comments, 10 CFR, Part 50 The intent of the Commission to improve the licensing environment for advanced nuclear power reactors is commendable. It is paramount that it be understood that this intent is not a goal to be worked toward but rather a necessary prerequisite to the serious consideration of such systems by the utility industry. In the concluding statement in the Summary, it is stated that "the Commission will keep the public informed of its judgment on the known and unknown safety aspects of advanced designs as they come before the Commission." Such judg-ments should be carefully expressed in terms of relative impacts on the public health and safety. It is not a proper regulatory role to unduly influence, positively or negatively, the selection of alternative concepts at the con-ceptual design stage. The licensing environment will facilitate public confidence only by a coopera-tive independence between industry and regulator. Independence must be estab-lished without aggressive adversarial confrontations.

\\ U. s. NUCLE R R Ot

Secretary of May 28, 1985 Page 2 the Commission Comments on Specific Commission Questions: Question 1 Should NRC's regulatory approach be revised to reduce dependence on prescrip-tive regulations and, instead, establish less prescriptive design objectives, such as performance standards? If so, in what aspects of nuclear power plant design (for example, reactor core power density, reactor core heat removal, containment, and siting) might the performance standards approach be applied most effectively? How could implementation of these performance standards be verfied? Comments The NRC's regulatory approach should be revised to reduce dependence on pre-scriptive regulations. Design criteria and the level of proof necessary to demonstrate compliance with the design criteria should be established early in the development stage of advanced concepts. Performance standards in specific areas may be an appropriate adjunct to design criteria if a direct relationship to public health and safety is established. Performance stand-ards beyond the public health and safety area may be of vital importance to the industry but are not a proper concern for the NRC. In any event, simply shifting from current design oriented regulations to performance standards is not a guarantee of lack of prescription. In the past and present regulatory environments, establishment of design criteria led to more requirements limiting or dictating how the design criteria must be met. It is equally likely that established performance standards would be followed by requirements dictating how the standards would be met. The management structure within NRC and industry, and the methods of inter-action between regulator and industry, must be examined to facilitate a coop-erative independence which will reduce the real or perceived need for prescip-tive regulations. Question 2 Should the regulations for advanced reactors require more inherent safety margin in their design? If so, should the emphasis be on providing features that permit more time for operator response to off-normal conditions, or should the emphasis be on providing systems that are capable of functioning under con-ditions that exceed the design basis? Comments Inherent safety is a term that is difficult to define, and if not carefully defined, can lead to arbitrary requirements. Operator response time should be carefully considered and should be consistent with the complexity of system design coupled with the diagnostic capabilities provided.

Secretary of the Commission May 28, 1985 Page 3 Capabilities beyond the design basis should not be required. The design basis should be carefully established based on system characteristics and the estab-lished safety goals. Events beyond the design basis should be considered only in light of the established safety goals. Question 3 Should licensing regulations for advanced reactors mandate simplified designs which require the fewest operator actions, and the minimum number of components needed for achieving and maintaining safe shutdown conditions, thereby facili-tating operator comprehension and reliable system function for off-normal conditions? Comments Licensing requirements mandating "minimum components" would of and should not be imposed. Question 4 "simplified design", "fewest operations", necessity be prescriptive and arbitrary Should the NRC develop general design criteria for advanced reactors by modi-fying the existing regulations, which were developed for the current generation of light water reactors, or by* developing a new set of general design criteria applicable to specific concepts which are brought before the Commission? Comments A set of general design criteria should be established to assure protection of the health and safety of the public. Specific design criteria should be avoided since they would become progressively more restrictive and may totally bias the options pursued. Question 5 Should the NRC favor advanced reactor designs that concentrate the primary safety functions in very few large systems (rather than in multiple subsys-tems), thereby minimizing the need for complex benefit and cost balancing in the engineering of safe reactors? Comments Favoring advanced designs that concentrate primary safety functions into a very few large systems as opposed to several smaller systems is not appropriate. Such choices are more properly engineering and management decisions based on design safety margins, operator response times, economics, and other factors including a defense in-depth philosophy.

Secretary of the Commission May 28, 1985 Page 4 Question 6 What degree of proof would be sufficient for the NRC to find that a new design is based on technology which is either proven or can be demonstrated by a satisfactory technology development program? For example, is it necessary or advisable to require a prototypical demonstration of an advanced reactor con-cept prior to final licensing of a commercial facility? Comments The need for a prototypical demonstration of an advanced reactor is dependent upon the extent to which a particular concept relies upon unproven technology. Confidence in a new concept will be an important factor to industry as well as the regulator. Determining the degree of proof required to demonstrate that a design meets the applicable regulatory requirements must be a part of the early interaction between industry and the NRC. A collective judgment will be necessary on a specific concept basis. It should be realized that a determination that prototypical demonstration is required may significantly impact the choice of a particular concept. We appreciate this opportunity to provide you with our comments. We trust that our comments will be considered and that the commission will move promptly to complete this package of rulemaking. I f there are any questions or problems concerning this subject, please advise. Very truly yours, £g~l-&J Hal B. Tucker JWD:smh

OOCMIIIUM8IRPR * ~ RULE -*5°0_ °' c.~ t - v.v G E N E R A L

• EL E CTR I C FR., I I Bf#;..}

NUCLEAR SYSTEMS TECHNOLOGY OPERATION GENERAL ELECTRIC COMPANY* 175 CURTNER AVENUE, M/ C

• SANJOSE, CALIFORNIA 95125 * (408) 925-May 24, 1985 MFN/f 078-85 Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention:

Docketing and Service Branch

SUBJECT:

COMMENTS ON PROPOSED POLICY FOR REGULATION OF ADVANCED NUCLEAR POWER PLANTS OOC:KEiED USNRC

• as HAY 30 All :54 Herewith are the General Electric Company comments on the Proposed Policy for Regulation of Advanced Nuclear Power Plants which was noticed in the Federal Register, Volume 50, No. 58, March 26, 1985.

General Electric supports the proposed policy statement and urges its adoption by the Commission. General Electric has long been a proponent of improving the licensing environment as evidenced by our active participation in the Commission's program for standardization of nuclear power plants, and by GE's endorsement of licensing reform legislation which is currently before Congress. The proposed policy certainly forms a basis for improving the licensing environment for the future generation of nuclear power reactors. While General Electric supports the proposed policy statement, the attached general comments and answers to the six questions are offered. Very truly yours, Glenn G. Sherwood, Manager Nuclear Safety & Licensing Operation

U.S. t-4tir1~f.D nrl"'*tl t,.Tf"'"' roMMtSsO' oorlT r ~\\I t **.. ~cnoM I ~,llV 0 \\ '1 ' ,QM D * ~ nne1,t c * *,tic* Posttn8r'.- {) -i ~e Coi:. ,..d :* I \\ ion --

GENERAL ELECTRIC COMMENTS AND ANSWERS TO QUESTIONS ON PROPOSED POLICY FOR REGULATION OF ADVANCED NUCLEAR POWER PLANTS

GENERAL COMMENT

S Clarification of Scope The scope of the policy needs clarification. The summary of the policy defines advanced reactors as reactor designs which are significantly different from the present generation light water reactors (LWRs). This implies that any non-LWR automatically qualifies as an advanced reactor. It also implies that an applicant must demonstrate that his design is significantly different from the present generation LWR, before it would qualify as a advanced reactor. The body of the proposed policy suggests that an advanced reactor is a reactor design with some or all of the five listed general characteristics. We do not consider that these "definitions" are adequate for this policy. The scope of the policy must be clarified by appropriately defining an advanced reactor.

Alternate Approach to Obtain Regulatory Approvals The policy should make provisions for obtaining regulatory approval of an advanced reactor by demonstrating its performance as substitution for the current practice of reviewing it against regulatory criteria. The scope and data requirements for testing to demonstrate performance would be developed by the NRC as part of its review of a specific application. Such an alternate review procedure would go a long way toward the policy goal of minimizing complexity and adding stability and predictability in the licensing of advanced reactors. Further, the option of demonstrating performance by testing would encourage applicants to utilize most of the five general characteris-tics, which the Commission believes are desirable for advanced reactors. RESPONSES TO QUESTIONS POSED BY NRC NRC Question 1 Should NRC's regulatory approach be revised to reduce dependence on prescriptive regulations and, instead, establish less prescriptive design objectives, such as performance standards? If so, in what aspects of nuclear power plant design (for example, reactor core power density, reactor core heat removal, containment, and siting) might the performance standards approach be applied most effectively? How could implementation of these performance standards be verified.

Answer to NRC Question 1 The NRC's regulatory approach should be revised to reduce dependence on prescription regulations. More emphasis should be placed on a prescrip-tive regulatory process. It is generally held that currently the NRC practice is too prescriptive and that the practices are also in need of change. The logical consequence is to suggest that less prescriptive regulations should be developed. In contrast, plant standardization is being pursued to ease the regulatory burden and this tends to make the process more prescriptive. Prescriptive regulations versus non-prescriptive regulations may not be the right question to ask when focusing regulatory revisions. We believe efficiency and consistency in the quality of the review can be improved by developing a prescriptive process for regulation. We also believe it is desirable to establish quantified safety goals, such as those published in the trial safety goals. There are other top-level requirements such as radiation dose to workers that should be prescribed. Similarly there is a need to specify the information required for review and to assure that the safety goals are being achieved. In summary, we are supportive of a prescriptive regulatory process and do not support the NRC prescribing design requirements. NRC Question 2 Should the regulations for advanced reactors require more inherent safety margin in their design? If so, should the emphasis be in provid-ing features that permit more time for operator response to off-normal

conditions, or should the emphasis be in providing systems that are capable of functioning under conditions that exceed the design basis? Answer to NRC Question 2 We believe that reactor designs which incorporate inherently safe responses to accidents should be encouraged. However, the term "inher-ent safety margin" is not defined in the policy statement and can be misinterpreted. Use of the more common terminology, "safety margins," would be better. We do not believe that more emphasis on "safety margins," is the best way to characterize the improvements we are seeking. It may be better to direct our attention to reducing uncertainty in the safety assessments. We consider that providing time for operator response to off-normal conditions is more desirable than providing systems that are capable of functioning under conditions that exceed the design basis. However, neither appear to be appropriate candidates for high level regulatory requirements. Recent assessments of the current generation of LWRs emphasizes the importance of these characteristics. However, these characteristics may be less significant in advanced systems designed to require little or no operator attention during accidents. It is there-fore recommended that a higher level objective that delays or avoids the necessity for operator action and simplicity of design to reduce the opportunity for operator error should be encouraged. Requirements for providing margins for events beyond the design basis should be part of the evaluation of risk. Decisions related to specific features should

be dependent on the importance such features have in reducing control-ling risk. These should not be arbitrarily emphasized by a policy statement. NRC Question 3 Should licensing regulations for advanced reactors mandate simplified designs which require the fewest operator actions, and the minimum number of components needed for achieving and maintaining safe shutdown conditions, thereby facilitating operator comprehension and reliable system function for off-normal conditions? Answer to NRC Question 3 We do not believe that the NRC should mandate design characteristics such as simplified designs. We do believe that it is appropriate for the policy to encourage design simplification which would place less demand on the operator under emergency conditions. Reduction in the number of systems and components required to maintain safe shutdown conditions is also a good objective from both a cost and a simplification viewpoint. It would not be effective to mandate these characteristics since such mandates may produce both uneconomical design and could carry premature commitments of regulatory acceptance. While the policy is moving in the proper direction it should avoid solution jumping in design specific areas.

NRC Question 4 Should the NRC develop general design criteria for advanced reactors by modifying the existing regulations, which were developed for the current generation of light water reactors, or by developing a new set of general design criteria applicable to specific concepts which are brought before the Commission? Answer to NRC Question 4 We believe that the NRC should develop a new set of general design criteria and requirements for this clan of nuclear reactors. Some of the current LWR problems have resulted from proceeding to codify or document requirements prematurely to solve an immediate singular problem and thereby have established a permanent precedent which is exceedingly difficult to revise. The NRC should require that the advanced reactor designer provide the detailed requirements they are using. These may be different depending on the design approach but would provide and assure adequate safety. We would recommend that NRC consider what criteria or regulatory process might be used to judge the adequacy of advanced reactor designs. NRC Question 5 Should the NRC favor advanced reactor design that concentrate the primary safety functions in very few large systems (rather than in multiple subsystems), thereby minimizing the need for complies benefit

and cost balancing in the engineering of safe reactors? Answer to NRC Question 5 We do not believe that the NRC should favor designs which focus safety in very few large systems. Whether single large safety features or many subsystems are used, the requirements should be based on economics as wel l as safety. The NRC should concentrate on establishing how to judge the safety adequacy of a design as opposed to attempting to prescribe design solutions. A concept which is designed so that the safety can be demonstrated with a high level of confidence should be judged more favorably. NRC Question 6 What degree of proof would be sufficient for the NRC to find that a new design is based on technology which is either proven or can be demon-strated by a satisfactory technology development program? For example, it it necessary or advisable to require a prototypical demonstration of an advanced reactor concept prior to final licensing of a commercial facility? Answer to Question 6 We believe the policy should encourage the development of the regulatory requirements and procedures to which allow the actual demonstration of safety performance as a substitute to the regulatory process. As

previously mentioned, we believe that a viable approach to improving the regulatory process would be one which allows the use of testing to demonstrate performance characteristics rather than the current practice of reviewing t he design against regulatory criteria. The degree of proof and the specific technology development program required will be dependent on the concept but at a minimum, we believe that inherent features should be fully demonstrated prior to issuing regulatory approvals.

ECOLOGY / ALEH' 1'

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-/1 //J'i O~ewosfO RULE - ~~ & BOX 62 T BLOOMSBURG 17815 (5a/#£ !IBBij 1 E Nernethy, Sec'y May 24 -85 Secretary - NRC Re: Proposed ~ Jle - H.egu1Etion of Advance Power Plants ATT: DOCKETING & SERVICE BRANCH Fed Re g - Mar 26 - p 11882 Gentlemen = DOC:KETU Nevertheless, he ~~Rioes: You may find the followin g comments naive. 1 - 2 - In your discussion of advance power plants, it's n c:ltfti~o if the 1RC has finally given up on the idea of cooling ra~t-All,22 breeder reactors with liquid sodium. It has seemed to us for the past eeveral years thaib~\\ti\\Efs1~tirr conceived the notion oi cooling a hot reactor with a v.iaRl~m;, unstable element like sodium is a choice caadidate for inten-sive care in a rubber room. Re: Questions 2 and 5: Should the regulatio~s require more inhereent sa~ety margins with more time for operator response, and should designs concentrate primary safety functions in a few large systems, rather than multiple subsystems? You've put your finger on a reactor's weakest link - the con-trol room operators. As humans, they ' re ~mlllkJmmm prey to boredom, aches and pains, hangovers, and worries about their personal problems. Any of these could distract them from their job of watching all those buttons, levers and blinking lights. The concept of "defense in depth", with multiple safety systems, simply adds to the numbers of. buttons, levers and blinking lights. As one finds in autos wi th all t he options - the automatic shi f t, the power steering, the push-button windows - the more gadgetry you 've got, the more damned stuff there is to go haywire. Thereofre, we suggest the NRC consider changing the emphasis from "defense in depth" to simplifying reactor design, pla cing the core at least 10 ft underground, and doubling the thickness of the containment. 3 - Jan 25-85, a/local item said PPL's Susquehanna Unit 1 was shut down automa tical ly on June 13-84, when lighning hit a high-voltage tran smission line. In October, "NRC inspectors learned *** the three fastest control rods were.012 seconds l a te in reaching the first of four shutdown positions." 4 - PPL was givena violation notice because plar t opera tors di dn't realize t he problem for months. The NRC said PPL should have declared the reactor inoperable until the problem was analy zed. This leads us to wonder if computers a.t reactors might be pro-grammed to be activated only' whe n something 's wron g - like a twelve-hundredth of a second delay in shu t ting down? (Our im-pression, which could be wrong, is that computers constantly spew a stream ot prin~outs) Could robots be designed to keep a beady eye on the key positions of the instrument panels? Finally, Que sti on 6: Should t here be a fYprDtotypeKJe onstr~on of an a dvanced reactor before it's licens ? ~ Affirmative! \\

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I INTERNATIONAL ENERGY ASSOCIATES LIMITED May 16, 1985 Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTN: Docketing and Services Branch

Dear Sirs:

'85 0 C:KETEO USNRC HAY 28 P12 :51 FF!LE' Or SE.CR!: TA~.'. DOCKET ING & Sf:fN1r;r BRANCH This letter is to transmit comments on the NRC's Pro-posed Policy for Regulation of Advanced Nuclear Power Plants, Federal Register, Vol. 50, No. 58, March 26, 1985. The comments are those of the ASEA-ATOM com-pany, designer of the PIUS reactor, which we represent in the United States. ASEA-ATOM perceives the statement as an excellent paper that serves to broaden the discussion of objec-tives for advanced reactors. They are pleased to find that the Commission's general intentions and objec-tives are so closely matched to what ASEA-ATOM has envisioned for PIUS. The ASEA-ATOM comments that are enclosed are phrased in response to the six specific questions raised by the Commission in the Proposed Policy. They are of-fered with the hope that the next version of the Pol-icy will serve to address additional issues, thus stabilizing further the future regulatory outlook for the designers of new concepts. Thank you for this opportunity to comment. lb~ J n C. /You~i_} J?'residept enclosu~e : as stated /zs 2600 VIRGINIA AVENUE, N.W. WASHINGTON, D.C. 20037 202 - 342 - 6700 Telex 89-2680 Cable IEAL WASHDC MAY 2 9 19 ,.,_ nm>ie<l80d by con.I. * *** *******.*.,.~

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ASEA-ATOM RESPONSE TO NRC PROPOSED POLICY FOR REGULATION OF ADVANCED NUCLEAR POWER PLANTS Question i: Should NRC's regulatory approach be revised to re-duce dependence on prescriptive regulations and, instead, estab-lish less prescriptive design objectives such as performance standards? If so, in what aspects of nuclear power plant design (for example, reactor core power density, reactor core heat re-moval, containment, and siting) might the performance standards approach be applied most effectively? How could implementation of these performance standards be verified?

Response

The NRC general design criteria and regulatory guides are written for the existing types of LWR plants and, if applied to advanced reactor designs, would severely limit the designer's possibilities to attain the goals which the NRC describes for advanced reactors. Most NRC staff members with whom we have discussed PIUS plant design features have not been overly prescriptive and have taken an approach which is oriented towards performance standards. It would of course be easier for the designer of advanced nuclear reactor plants if the design criteria could be made performance related. Th.e most important matter to note in our mind is that inherent safety features can seldom if ever be made redundant. Added engineered safety systems may jeopardize the inherent feature rather than supplement it. NRC can stimulate innovation, while controlling the overall level of safety to be achieved in future plants, by relying more on performance standards and less on prescriptive requirements. NRC will still have access to and approve the details of a particular design through NRC's certificaton of each standard design by rulemaking. The performance standards could well serve to address siting, containment, and emergency planning, perhaps through the establishment of 11e. minimus risk criteria. These subjects will be especially appropriate for advanced reactors where designers endeavor to improve the inherent safety 1

of their concepts and reduce reliance on engineered safety fea-tures or consequence mitigation schemes. The roles of NRC's safety goal and of probabilistic risk assessment should also be addressed in establishing such performance standards. The question raised about verification of performance standards is very important indeed, and testability should possibly be given an equal status with simplicity in the formulation of de-sirable characteristics of advanced reactors. Implementation of performance standards can be verified in ways other than test-ing, including the following: (1) NRC review of design quality assurance and of proced~ral details in the process of certifying standard design, construction, and manufacturing activities; (2) NRC review of the results of safety tests of first-of-a-kind plants or special non-nuclear test facilities to demonstrate their inherent safety for design basis events; and (3) NRC li-censing of individual utilities that reference the certified designs in applications for site permits or operating licenses for specific plants. Question 2: Should the regulations for advanced reactors re-quire more inherent safety margin in their design? If so, should the emphasis be on providing features that permit more time for operator response to off-normal conditions, or should the emphasis be on providing systems that are capable of func-tioning under conditions that exceed the design basis?

Response

Yes, NRC regulation of advanced reactors should re-quire more inherent safety margin in design. For example, no heroic measures should be expected of operators to protect either the capital investment or public safety. The goals should be to achieve passive safety characteristics in the de-sign and the inherent progression of the plant from unstable to stable shutdown and cooling under all upset conditions and for all credible external hazards. If these goals are contained within the design basis and if the risk from extreme phenomena that lie outside the design envelope is less than some.de. 2

minimus value, then there is no need to require or to provide systems capable of functioning under conditions that exceed the design basis. Question 3: Should licensing regulations for advanced reactors mandate simplified designs which require the fewest operator ac-tions and the minimum number of components needed for achieving and maintaining safe shutdown conditions, thereby facilitating operator comprehension and reliable system function for off-normal conditions?

Response

We believe that such mandates are important, not only in order to attain a higher level of plant safety but also in order to achieve public acceptance of the plants. However, it is unnecessary for NRC to reguire simplicity. Rather, inherent safety will yield simplicity. Inherent safety characteristics that assure the basic safety functions for the plant whenever it is in an unstable state cannot depend on operator action or com-plex, add-on safety features. Thus, NRC should mandate perfor-mance standards implied in question one and leave the design details to the designers. If the result is too complex to be workable, NRC will see it in the details of its certification review or in lead plant test results. In fact, LWRs weren't so complex in the beginning. Only after years of changes in de-signs, safety objectives, licensing reviews, inspections, etc. did the situation become too complex. Starting anew with a de-sign certified to meet a specified, acceptable safety goal would do much to achieve the desirable characteristic of design sim-plicity, especially if the design is inherently safe, which of course it should be. Beyond this, the NRC should consider a goal for advanced reactors that have "walk away" safety. That is, perhaps the plants should inherently revert to safe, long-term, cold shutdown conditions with assured core cooling even if the reactor operators "walk away" for any of the design basis events. Question 4: Should the NRC develop general design criteria for advanced reactors by modifying the existing regulations, which were developed for the current generation of light water 3

reactors, or by developing a new set of general design criteria applicable to specific concepts which are brought before the Com-mission?

Response

As we have said under question 1, new criteria would be an advantage, and we believe that the performance standards approach suggested there is the way the NRC should proceed. Such criteria may well develop into prescriptive regulation through design certification for a new type of reactor, once it has proved itself and found a market. If resources do not permit NRC to proceed with new criteria at this time, then NRC might encourage the proponents of advanced reactor designs to propose General Design Criteria (GDC) appli-cable to their individual situations. These can be analyzed with respect to or evolved from the existing criteria of 10 CFR 50 Appendix A to help assure completeness. These new design criteria would be reviewed and approved by NRC, but they need not be established as general rules of NRC. Rather, they could be formally approved as specifically applicable design cri~eria for a particular design when that design is certified by NRC rulemaking. This should give the criteria the same status and enforcability as the current GDC. Asking the proponents to pro-pose criteria for NRC review and approval provides an incentive for designers to build safety into their reactor concepts while permitting NRC to maintain regulatory oversight of the end re-sult. Question 5: Should the NRC favor advanced reactor designs that concentrate the primary safety functions in very few large sys-tems (rather than in multiple subsystems), thereby minimizing the need for complex benefit and cost balancing in the engineer-ing of safe reactors?

Response

PIUS designers are in favor of concentration of the primary functions in a few systems. We have found the approach effective. 4

Question 6: What degree of proof would be sufficient for the NRC to find that a new design is based on technology which is either proven or can be demonstrated by a satisfactory techno-logy development program? For example, is it necessary or ad-visable to require a prototypical demonstration of an advanced reactor concept prior to final licensing of a commercial fa-cility? RespoD.§~: The answer depends on how far the new design deviates from existing proven designs. One alternative is a large pro-gram of separate effects research. Another is a prototypical demonstration. In the case of PIUS, a non-nuclear demonstration plant should suffice to prove the safety and viability of the concept. A feature of a demonstration facility, either nuclear or non-nuclear, might be special instrumentation to permit the veri-fication of design codes and accident analysis codes. This would remove the need for much detailed licensing review on subsequent plants, thus saving NRC resources and helping the manufacturer use subsequent sales to pay back its initial investment. 5

_.._11PR L7I IUII , ~ :;,;u C-=ia m ttl8',2;,,J *@ San Diego Gas & Electric May 17, 1985 Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Docketing and Service Branch

Dear Sir:

FILE NO. DOCKETED USNRC

• as HAY 28 All :42 OFFtC.E OF SECRI:. TAh Y DOCKETING & SERVICf BRANCH The San Diego Gas & Electric Company is pleased to respond to the request for comments of the NRC on the Proposed Policy for Regulation of Advanced Nuclear Power Plants published n the Federal Register notice, Vol. 50, No. 58, March 26, 1985.

SDG&E is co-owner and co-licensee of the 3-unit San Onofre Nuclear Generating Station and actively supports nuclear R&D via its association with EPRI, GCRA, etc. We are supportive of the position that the United States urgently needs to assure the viability of the nuclear option to satisfy future electric generation requirements. In this light, we support the NRC's initiative in examining the licensing and regulatory framework that should be in place for advanced nuclear reactor concepts. General Comments on Proposed Policy Statement The policy statement seems to require emphasis (for new concepts) on "an enhanced margin of safety." We are concerned that, by implication, such emphasis denigrates the safety of current designs, and raises needlessly expectations for new designs. Neither implications are accurate, nor desirable. Since quantification of "enhanced lllargin 11 is difficul t, the NRC should avoid speculative and subjective judgments such as these, for it is precisely the imprecision of such a requirement that has contributed so disastrously to the current licensing framework, i.e. retrospective searches for enhanced safety margins. The NRC should strive to state, as in the safety goals effort, what is adequate and "stick to it"! The summary statement says: " -- the Commission will keep the public informed of its judgment on the known and unknown safety aspects of advanced reactor designs as they come before the Commission," and then, 11 -- policy is to encourage the earliest possible interaction of applicants, vendors, other government agencies nd the NRC ---". These "motherhood" statements are antithetical, since premature disclosure of design details, before being fully analyzed and verified, raises expectations, which POST OFFICE BOX 1831

• SAN DIEGO, CALIFORNIA 92112
• TELEPHONE: 619/696-2000

I u. s. NUCL AR REGULATORY C0MMISSIOI'-( 0 ,t.

SECRETARY OF THE COMMISSION subsequently may require substantial modification to be viewed by the regulators and the anti-nuclear activists as equivocation. Also, early interaction invites critical assessment before all design features are fully coordinated into a defensible, validated whole. The NRC should take care to minimize opportunities for demagoguery and the fostering of misconceptions. The proposed policy notes the desire of the NRC "to minimize complexity and add stability and predictability in the licensing and regulation of advanced reactors." These are highly desirable aims! Then, the NRC lists a number of general characteristics of new concepts that may be beneficial.

However, the NRC then suggests that "combination of some or all of them may help obtain early licensing or standardized design approval with minimum regulatory burden and should be more readily understood by the NRC, the utilities and the general public."

Why would these only "may help"? What inducements are there for applicants to apply such characteristics if demonstrable benefits cannot be assured? And, what does "should be more readily understood" mean? Specifically, the NRC should be prepared to describe how it proposes to "minimize complexity and add stability and predictability" in a convincing way. current practice (and prior experience) is not very comforting. "An advanced reactors group has been established -- and, will prepare a plan for the development of regulatory criteria for licensing proposed advanced reactors." The NRC should permit participation in this plan preparation by knowledgeable groups such as EPRI, INPO, NSAC, ACRS, AIF, etc. lest "the group" emulate current regulatory complexity. The Commissioners should provide firm guidelines for assuring a "better mousetrap"! Response to Specific Questions

1.

Yes. The new regulatory framework should eschew prescriptive provisions. Basic performance criteria should be defined, such as compliance with NRC Safety Goals and dose criteria of 10CFR 20 and 100. All other criteria (if any) should be con-cept-specific permitting credit to be taken for its inherent characteristics.

2.

The emphasis on "more inherent safety margins" is misdirected and counterproductive. The entire reliance on the design basis is undermined if additional margin is required for events "beyond the design basis." An adequate design basis, i.e. one that meets the Safety Goals and dose regulations, should be established and then, adhered to! Utility executives will not again subject their organizations to the uncertainties of an open-ended regulatory scheme.

3.

No. The NRC acknowledges that it is not a design

SECRETARY OF THE COMMISSION organization. Therefore, it is counterproductive for it (NRC) to "mandate simplified designs" since it is not equip-ped to know -- on an overall concept design basis -- what feature is actually a simplified design feature. One can simplify one system, but frequently only at the expense of added complexity in other systems! NRC should seek "systems engineering" solution to overall performance.

4.

A new set of general design criteria should be developed, not solely by NRC (as noted above), and should permit concept-specific characteristics to apply.

5.

No. As noted in Response 3, above, the NRC should leave design to the designers. If a given design meets the NRC general criteria, then the NRC need not "prompt" the designers to achieve other pre-conceived design objectives, since it is unlikely that consensus can be achieved even within the NRC Staff on the most desirable solution to a perceived need for improvement.

6.

How does NRC define the term "proof"? In whose judgment has "sufficient proof" been demonstrated by what sequence of analysis and testing activities? The NRC must remain as the judge of concept compliance with its regulations. If the NRC were to "require" demonstration, would they also require that the prototype plant be subjected to all the design basis accidents as "proof", even if the plant is destroyed in the process (although having no impact on public health and safety)? Would the NRC co-fund such "proof demonstration"? The term "proof" is totally inap-propriate. We continue to support the NRC in this effort and look forward to the evolution of a sound, balanced policy. ~c.~ f,,-,- L. Bernath Manager - Nuclear Dept.

... 11B -R PR Z). -- _IUl.f -j~.,(ij) (5?J F~ I I BBJ) S TONE & WEBSTER ENGINEERING CORPORATION BOSTO N NEW Y O RK C HE R RY H I LL. N. J. D EN V E R H O U S TON P ORTLAND. O R EGO N R ICHLAND, WA W AS HIN G T ON. D. C. 245 SUMMER STREET, BOSTON, MASSACHUSETTS AD D RESS ALL C O RRESPONDENCE TO P.O. B O X 2325. BOSTON. MA 02107 W. U. TE L E X, 9 4 -00 0 1 9 4 -097 7 OOtKETED USNRC

• as MAY 28 A11 :26 DES I GN C O N STR UCT I O N REPORTS E X AM IN AT I ONS C ON S UL TING E N G I N EER I NG Secretary of the Commission May 24, 1985 U.S. Nuclear Regulatory Commision Washington, D.C.

20555 OFFlCt OF SECRt._TA::._. OOCKE.TING & SEPVICf Attn: Docketing and Service Branch PROPOSED POLICY FOR REGULATION OF ADVANCE NUCLEAR POWER PLANTS 50FR11882 BRANCH This letter is in response to the Commission request for comments on the subject proposed policy statement, published in the Federal Register March 26, 1985. Stone & Webster Engineering Corporation (SWEC) is currently involved in the development of advanced reactor designs. We also were involved in HTGR designs which the NRC reviewed in the early 1970's. Accordingly, we are keenly interested in the Commission's policy for advanced reactors and we endorse the Commission's intentions to improve the licensing environment for advanced reactors and to minimize complexity and uncertainty in the regulatory process. To this end we specifically welcome the Commission's formation of an advanced reactors group, its encouragement of early interaction between applicants, vendors, other government agencies, and the NRC and its intention to maintain the capability to provide a timely assessment and response to advanced designs presented to the NRC for review. It is this process for interaction which we believe should be the primary focal point for the Commission's Policy Statement for Regulation of Advanced Nuclear Power Plants. In addition to its proposed policy statement, the Commission identifies and requests public comment regarding several general characteristics of an advanced reactor design which it believes would be desirable and could help in obtaining early licensing approvals and greater understanding by the public. Ostensibly, these characteristics, including simplified designs, greater inherent safety margin, and more reliable and maintainable plants are desirable goals which the designers of advanced reactors would no doubt strive for. However, we believe, as does the Commission, "that regulatory guidance must be sufficiently general to avoid placing unnecessary constraints on the development of new design concepts." This is especially true in the early stages of innovative or advanced concepts. At this time, to specify particular attributes of advanced reactors may eliminate concepts which could otherwise provide a better balance between safety, reliability and cost. We believe that the process for interaction between designers and the NRC that the Commission is proposing is the best means for evaluating the design characteristics most important to regulation of advanced reactors.

I u. s. NUCLEMl *'1~ DOCf' G_UU\\T?RY COMMISSIOl"i O

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Secretary of the Commission 2 May 24, 1985 In this context we have attached our responses to the six questions and several specific comments on the proposed policy statement. We would be pleased to meet with the Commission to discuss comments on the proposed policy statement. R~~ad ury Chief Engineer Nuclear Technology and Licensing Division Enclosure DRJ:amg

Secretary of the Commission SWEC'S SPECIFIC COMMENTS ON NRC'S PROPOSED POLICY FOR REGULATION OF ADVANCED NUCLEAR POWER PLANTS Attachment

1.

SWEC believes that the last sentence of the summary, beginning "As the agency... " and ending before ".*. the Commission will keep" should be deleted or expressed in terms of the NRC statutory mandate to protect public health and safety. The language used is imprecise and misleading when it speaks of potential hazards of nuclear power plants. The remainder of the sentence is unclear as to how the NRC will keep the public informed of "unknown safety aspects."

2.

The Commission indicates that it is preparing a separate policy statement on standardization which will apply to future reactors. It is in this separate policy statement that the Commission's goals on standardization should be expressed and the advanced reactor policy statement should only focus on advanced reactor policy. Accordingly, we believe that under Current Commission Policy the discussion on standardization, including the statement from the 1985 Policy and Planning Guidance should be deleted. We also believe the sentence "The Commission's ultimate goal is the approval of essentially complete standard plant designs" under Proposed Policy should be deleted.

3.

The Commission expresses its goals to add stability and predictability in licensing and regulation of advanced reactors. To achieve this the Commission must do more than is outlined in this policy statement. It also must streamline and rationalize its administrative licensing process.

4.

We believe that drastic departure from current designs should not be a pre-requisite for applying any streamlined licensing approach which evolves.

5.

The early interaction discussed in the policy statement must carry with it the obligation by NRC and industry to stand by the agreements reached during this process. NRC Question No. 1 Should NRC's regulatory approach be revised to reduce dependence on prescriptive regulations and, instead, establish less prescriptive design objectives, such as performance standards? If so, in what aspects of nuclear power plant design (for example, reactor core power density, reactor core heat removal, containment, and siting) might the performance standards approach be applied most effectively? How could implementation of these performance standards be verified? Answer to Question 1 We believe that NRC' s regulatory approach should reduce dependence on prescriptive regulations and instead establish other design objectives such as safety standards or goals. By moving away from prescriptive regulations, the NRC would be fostering more innovation in plant designs BD4-40143-57-la 1

Secretary of the Gonnnission Attachment and would allow plant designers to optimize design features which would contribute to safe, reliable and economical plants. Verification of implementation should be by applicant/licensee audits with appropriate NRG oversight. NRG Question No. 2 Should the regulations for advanced reactors require more inherent safety margin in their design? If so, should the emphasis be on providing features that permit more time for operator response to off-normal conditions, or should the emphasis be on providing systems that are capable of functioning under conditions that exceed the design basis? Answer to Question 2 Designs to an appropriate design objective using acceptable methodology will result in an optimization of overall plant safety that can be developed through the plant designer/NRG interactions. NRG Question No. 3 Should licensing regulations for advanced reactors mandate simplified designs which require the fewest operator actions, and the minimum number of components needed for achieving and maintaining safe shutdown conditions, thereby facilitating operator comprehension and reliable system function for off-normal conditions? Answer to Question 3 Regulations should not arbitrarily mandate simplified designs. In many instances simplification results in a safer design, but this is not always true and each design must be evaluated on a case-by-case basis. Again we believe that the interactive process that the Gonnnission is supporting will provide a better basis for answering this question. One concern though is how the Gonnnission would mandate simplified designs or assess the degree of simplification required. This would involve establishing both a baseline and a standard by which to judge simplification. What if simplification of one system required another to be more complex? We believe appropriate safety standards or goals would better lend themselves to an optimization of plant design. NRG Question No. 4 Should the NRG develop general design criteria for advanced reactors by modifying the existing regulations, which were developed for the current generation of light water reactors, or by developing a new set of general design criteria applicable to specific concepts which are brought before the Gonnnission? BD4-40143-57-la 2

Secretary of the Commission Attachment Answer to Question 4 One set of general design criteria (GDC) should apply to all reactor types. From these, type-specific safety standards or goals could be developed. We believe that the existing GDC, along with the experience already gained from the NRC's review of earlier advanced reactor designs, should form the basis from which the NRC should work. NRC Question No. 5 Should the NRC favor advanced reactor designs that concentrate the primary safety functions in very few large systems (rather than in multiple subsystems), thereby minimizing the need for complex benefit and cost balancing in the engineering of safe reactors? Answer to Question 5 The NRC should not be prescriptive and favor particular plant designs. The designer should have the flexibility to use the design philosophy that best achieves the goal of a safe, reliable, and economical nuclear power plant. NRC Question No. 6 What degree of proof would be sufficient for the NRC to find that a new design is based on technology which is either proven or can be demontrated by a satisfactory technology development program? For example, is it necessary or advisable to require a prototypical demonstration of an advanced reactor concept prior to final licensing of a commercial facility? Answer to Question 6 The degree of design verification by the NRC, including the need for prototypical demonstration or test, depends on the extent of departure from demonstrated technology. BD4-40143-57-la 3

C-E Power Systems Combustion Engineering, Inc. 1000 Prospect Hill Road Windsor, Connecticut 06095 E !!!!II!!!!! POWER iiiilliiiii SVSTE MS Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Te l. 203/688-1911 Telex: 99297 May 22, 1985 LD-85-026 DOCKETED USNRC

• as MAY 28 All :25 GFFIC: OF SECRt TAR'*

DOCKETING & SEf<VICf. 3RANCH

Subject:

Proposed Policy for Regulation of Advanced Nuclear Power Plants

Dear Sir:

Combustion Engineering (C-E) is pleased to offer its comments on the "Proposed Policy for Regulation of Advanced Nuclear Power Plants", as published in the Federal Register on March 26, 1985. In addition to our activities to improve upon the current generation of Light Water Reactors (LWRs), C-E is also involved in development programs for advanced reactor designs (e.g., High Temperature Gas-Cooled Reactors and Liquid Metal-Cooled Reactors). We are, therefore, pleased to see that the Commission is developing plans to review the new and innovative designs that are being developed by industry and the DOE. C-E understands that the advanced reactor policy will apply only to truly different designs, i.e., designs with significantly different characteristics, and not to evolutionary changes in LWRs. While the ultimate safety objectives should be the same for LWRs as for advanced reactors, the methods, procedures and criteria for meeting the objectives are not necessarily the same. For the advanced nuclear reactor designs, there is increased emphasis on inherent safety margin. Such aspects as time for operator response, margins between normal operating conditions and failure points, simplicity of safety-related systems and the ability to actually demonstrate upset conditions should be taken into account. C-E shares the Commission's expectation that "these reactor plants will have an enhanced margin of safety" and we agree that the five general characteristics listed in the proposed policy "would be desirable". We would go further to say that these goals are desirable for all future nuclear plants, including the next generation of LWRs. We caution the Commission, however, to keep these goals as desirable objectives and not develop them into new requirements. We believe that the level of safety found in current LWRs is more than adequate to protect the health and safety of the public. New plants, therefore, need not be held to a higher licensing standard. Recent events in the nuclear industry have demonsrated that nuclear power plants cannot remain economically viable if increased safety requirements are continually imposed without considering cost impacts. Designers of future nuclear plants already have financial incentive to provide improved safety, reliability and availability. The accident at

U. S. NUCLEAR RE"GI 11 ~r i1Y Co:\\ :,11SSION DOCK r*-; .,CH 0,

Secretary of the Commission May 8, 1985 LD-85-026 Page 2 Three Mile Island clearly demonstrated that a nuclear accident presents more of a threat to the financial health of the utility owning the plant than a threat to the health and safety of the public. The designers' goals, therefore, should be consistent with the NRC 1 s stated goals, but the designers must have the flexibility that they need to keep nuclear plants economically viable. Futher, Congress has not amended the Atomic Energy Act to require a higher standard of safety for nuclear plants. For the Commission to do so on its own would seem to contradict the efforts of the Commission and the Congress to restore confidence and stability to the licensing process. Our responses to the six questions asked in the Federal Register Notice are provided in the attachment to this letter. If you have any further questions, or would like to discuss our recommendations, please feel free to call me or Mr. G. A. Davis of my staff at (203) 285-5207. AES:las Attach. Very truly yours, COMBUSTION ENGINEERING, INC. ~~r Director Nuclear Licensing

QUESTION 1.

Response

RESPONSES TO QUESTIONS IN PROPOSED POLICY FOR REGULATION OF ADVANCED NUCLEAR POWER PLANTS LD-85-O26 Attachment Should NRC's regulatory approach be revised to reduce dependence on prescriptive regulations and, instead, establish less prescriptive design objectives, such as performance standards? If so, in what aspects of nuclear power plant design (for example, reactor core power density, reactor core heat remooval, containment and siting) might the performance standards approach be applied most effectively? How could implementation of these performance standards be verified? Yes, the NRC should reduce dependence on prescriptive regulations. This comment applies to the next generation of LWRs, as well as advanced reactor concepts. Although it is helpful for the NRC to use guidelines and standards, it is important that they allow for the flexibility that designers will need to develop new concepts which may maintain (or even improve) overall plant safety without increasing the uncertainty that the new concepts can be licensed simply because the new concept may not be covered by any of the "prescriptive" requirements of the NRC. Since it appears that future NRC review efforts will be devoted to a few standard designs, rather than a multitude of custom plant designs~ prescriptive regulations should not be necessary. The aspects of plant design that most influence public health and safety seem to center around decay heat removal (to avoid severe core damage) and offsite exposures resulting from postulated accidents. Implementation of performance standards are most readily verified by analyses (including probabilistic risk assessment) that are backed up by operational data, separate-effects tests and/or startup testing, where necessary. QUESTION 2. Should the regulations for advanced reactors require more inherent safety margin in their design? If so, should the emphasis be on providing features that permit more time for operator response to off-normal conditions, or should the emphasis be on providing systems that are capable of functioning under conditions that exceed the design basis?

Response

There should not be a requirement for more inherent safety margin in the design of advanced reactors. Designers should be allowed the flexibility necessary to keep nuclear plants viable. The inherent safety of the advanced reactor design, however, should be taken into consideration in the licensing process before requiring enhancement of the engineered safety features. We believe that designers should place emphasis on providing features that permit more time for operator response to off-normal conditions. QUESTION 3.

Response

Should licensing regulations for advanced reactors mandate simplified designs which require the fewest operator actions, and the minimum number of components needed for achieving and maintaining safe shutdown conditions, thereby facilitating operator comprehension and reliable system function for off-normal conditions? The characteristics listed in the proposed policy (e.g., simplified designs) should be desirable objectives, but are totally inappropriate to be mandated as new NRC requirements. Although the NRC should be concerned that a minimum level of safety is achieved, how it is achieved should be of concern to the designers and to the utilitiesthat will own and operate the plants. QUESTION 4.

Response

Should the NRC develop general criteria for advanced reactors by modifying the existing regulations, which were developed for the current generation of light water reactors, or by developing a new set of general design criteria applicable to specific concepts which are brought before the Commission? Current GDCs were written specifically for LWRs and are based on assumptions relevant to LWRs. Reactors not having features similar to LWRs should conform to a different set of GDCs while still achieving the same assurance of safety to the public. Naturally, in some areas, there may be overlap of applicable GDCs. QUESTION 5. Should the NRC favor advanced reactor designs that concentrate the primary safety functions in very few large systems (rather than in multiple subsystems), thereby minimizing the need for complex benefit and cost balancing in the engineering of safe reactors?

.. Response If the safety of the reactor concept relies upon relatively few, simple and demonstrable characteristics, this will result in less uncertainty in the conclusions. This should certainly be taken into account. QUESTION 6.

Response

What degree of proof would be sufficient for the NRC to find that a new design is based on technology which is either proven or can be demonstrated by a satisfactory technology development program? For example, is it necessary or advisable to require a prototypical demonstration of an advanced reactor concept prior to final licensing of a commercial facility? Some advanced reactor designs are capable of performing realistic demonstrations (in lieu of analyses) of performance under accident conditions. Applicants, therefore, should be allowed the option of performing the tests in place of analyses. Prototypical demonstration, however, should not be required to license a new design. As noted in the response to Question 1, it should also be possible to verify the safety of a new design by analyses that are backed up by separate-effects tests and/or startup testing, where necessary. Only if the tests failed to substantiate the assumptions in the analyses should it be necessary to re-open the NRC approval of a new design.

Mr. Samuel J. Chilk Secretary of the Commission GAS-COOLED REACTOR ASSOCIATES 10240 Sorrento Valley Rd., Ste. 300 San Diego. CA 92121-1605 ( 619) 455-9500 May 24, 1985 U.S. Nuclear Regulatory Commission OOC.:KETED USNRC 985 HAY 28 All :19 ~ Washington, D.C. 20555 Attention: Docketing and Service Branch ,**FF'C:- OF SECPE'i'.6.R" u I '-

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Subject:

Comments on Proposed Policy for Regulation of Advanced Nuclear Power Plants

Dear Mr. Chilk:

This letter provides Gas-Cooled Reactor Associates (GCRA) comments on the Commission's proposed policy statement on advanced nuclear power plants. GCRA is a utility/user organization that represents approximately one third of the U.S. generation capacity plus a number of potential industrial users who are interested in the development and commercialization of the gas-cooled reactor in this country. As such, the attached comments were developed by the GCRA staff with review and input from our member utilities. We endorse and are encouraged by the overall intent of the commission in preparing the proposed policy and feel that its issue, following resolution of

comments, would aid the development of advanced reactor technologies, such as the HTGR.

In particular, we strongly support the Commissions stated intent to consider factors "important for advanced reactor concepts in order to minimize complexity and uncertainty in the regulatory process," to leave regulatory guidance "sufficiently general to avoid placing unnecessary constraints on the development of new design concepts," and to encourage NRC staff interaction on advanced designs "as far in advance of application as practicable." Our principal concern with the proposed policy, as elaborated on in the enclosed, is the implication that future power plants will be required to have "increased safety margins." Such a statement can be interpreted to imply that future reactors will be required to meet stricter safety criteria than current generation designs.

Instead, we believe the objective of our advanced reactor design efforts is to attain comparable levels of safety in a simpler and more demonstrable fashion.

We believe that the Commission's position on this issue needs to be clarified in the final policy otatement.

Ct.r., RY, SSIO'

Mr. S. J. Chilk May 24, 1985 Page 2 of 2 \\ Consistent with the proposed policy statement, we look forward to the Commission's continued cooperation in the review of the HTGR A concept and would be pleased to provide additional details on our comments if required. APK:fd cc: GCRA Management Committee GCRA Technical Advisory Committee Jerry Griffith, DOE/HQ Ray Ng, DOE/HQ Len Lanni, DOE/SAN Dick Dean/Fred Silady, GA Sam Armijo/Neil Brown, GE Warren Chernock, CE Sim Golan/Stan Lynch, BNI Bill Sheridan/Lloyd Walker, SWEC V Sincerely, L. D. Mears General Manager

GCRA COMMENTS ON PROPOSED POLICY FOR REGULATION OF ADVANCED NUCLEAR POWER PLANTS The following comments are in regard to the NRC Proposed Policy statement on advanced nuclear power reactors, as published on page 11882 of the Federal Register on Tuesday, March 26, 1985. COMMENTS ON THE POLICY STATMENT

1.

As identified in the "Licensing Plan for the Standard HTGR" which has been submitted to the NRC by the Department of Energy, we believe the NRC policy statement should focus on the following issues which are of importance to near term design activities: a) Whether top-level licensing criteria (i.e. public dose and risk criteria) for advanced reactors should be different than for current generation reactors. b) Whether the NRC should consider alternative proposed for deriving design specific lower-level criteria (e.g. Design Criteria) from these top-level criteria which account unique safety characteristics of advanced reactors. methods General for the c) Whether the NRC proposed advanced reactor construction permit. should commit staff resources to review designs prior to formal application for a As drafted, we believe the policy statement explicitly addresses both issues b) and c). The NRC appears to be favorably inclined to consider new design specific criteria for advanced reactors which account for unique safety characteristics and the policy definitely encourages early interaction on the evolving concept designs. On issue a), the policy statement is not explicit. There, however, is a frequent use of terms like "increased safety margins" which could be interpreted to imply that future reactors will be required A to meet stricter safety criteria than current generation reactors. We believe that this would be most undesirable. The focus of advanced reactor design efforts should be to,

instead, attain comparable levels of safety in a

simpler and more demonstrable fashion which may ultimately result in a more economical product. Consistent with the

above, we believe that regulatory uncertainty will continue to plague the industry until clearly defined safety goals are adopted by the NRC for all reactors.

Before design level criteria can be specified for a given reactor concept, it is essential that the regulator be able to define the acceptable level of risk the designer or manufacturer must achieve.

2.

The policy statement does not provide details on the format and procedure for submittal of technical information on proposed conceptual designs as far in advance as possible. Can it be assumed that guidance provided from the advanced reactor group will, in fact, be applied later if an applicant submits a PSAR using the new concept? Will meetings, question and answer exchanges, and SER's be 1

used in a similar way to the PSAR stage? information on a concept or could a pursue licensing collectively? approvals/judgments take? Must a single entity submit group of interested parties What form would early

3.

The NRC provides a specific list of features it would like to see in advanced designs, but gives no specifics as to how these features will "help obtain early licensing or standardized design approval with minimum regulatory burden." Some examples should be listed to clarify how these design features might result in such regulatory benefits.

4.

In the summary it is stated that, "It is anticipated that these designs will reflect the benefits of significant research and development

work, and include the experience gained in operating the many power and developmental reactors both in the United States and throughout the world".

In order for the designs to reflect A experience from outside the United States, it will be necessary for the NRC to accept data generated in other countries. Thus, the policy should include a statement to the effect that the NRC will actively pursue the development of mechanisms for the timely and effective incorporation of data from other countries into the licensing process. RESPONSES TO QUESTIONS

1. Question:

Should NRC's regulatory approach be revised to reduce dependence on prescriptive regulations

and, instead, establish less prescriptive design objectives, such as performance standards? If so, in what aspects of nuclear power plant design (for example, reactor core power density, reactor core heat removal, containment, and siting) might the performance standards approach be applied most effectively?

How could implementation of these performance standards be verified?

Response

Yes, the dependence preferable NRC's regulatory approach should be revised to reduce on prescriptive regulations.

Performance standards are to the current regulatory regime. These standards should be expressed in terms that are independent of current technology. For

example, limits on parameters like power density should be avoided, since they are based on limits of systems and materials which may, in the future, be improved.

Most important, the standards should avoid prescription for the performance of subsystems in order to permit the maximum flexibility in achieving the standards through integrated plant design. For

example, a core heat removal standard should be expressed in terms of the overall design's core heat removal capability, not performance of a designated core heat removal sub-system.

2

It is essential that the Commission avoid the temptation to subdivide the performance standards by subsystem or event. These subdivided standards drastically reduce the ability of the designer to optimize the safety prformance of the overall plant system. The performance standards adopted must be consistent with other aspects of regulatory policy. It is essential that they be consistent with the safety goal, and the establishment of performance standards offers the opportunity to either reinforce the existing defense-in-depth approach or to enhance it by adopting a functional approach. Extension of the existing approach to defense-in-depth A would establish separate performance standards for the independent W systems. (These are,

loosely, the core protection, containment,

siting, and emergency response program systems.)

The functional alternative, for

example, in the case of containment performance, would be to establish a criterion for non-release of radionuclides and allow the designer to demonstrate the adequacy of any proposed alternative to a containment building for meeting the criterion.

Implementation of performance standards can be verified in two ways: review of the design by the NRC staff and technical qualification of the vendor/AE/applicant team. Demonstrating technical capability has been under utilized as a means of ensuring quality control. Dependence on the ability to produce written QA programs has weakened the overall performance of quality work.

2. Question:

Should the regulations for advanced reactors require more inherent safety margin in their design? If so, should the emphasis be on providing features that permit more time for operator response to off-normal conditions, or should the emphasis be on providing systems that are capable of functioning under conditions that exceed the design basis?

Response

a No. Current safety margins are demonstrably adequate to assure W public health and safety, which is as far as the design purview of the NRC extends. Neither should regulation prescribe the methods to be used for achieving safety margin. Future plant owners/operators can be expected to demand more forgiving systems for purely economic reasons if the use of inherent features in the design is allowed to offset the need for other engineered features. Requiring that systems be designed to perform under conditions "exceeding the design basis" is a contradiction in terms. 3

3. Question:

Should licensing regulations for advanced reactors mandate simplified designs which require the fewest operator actions, and the minimum number of components needed for achieving and maintaining safe shutdown conditions, thereby facilitating operator comprehension and reliable system function for off-normal conditions?

Response

No. As achieving designer acceptable noted in the previous responses, the design methods of safety should be left to the designer to establish. The also bears the burden of demonstrating, in a manner to the regulator, that the methods will be effective.

However, it is strongly suggested that the Commission, through regulatory guidance and by offsetting the need for detailed technical specifications and operational procedures, encourage the use of 4I simplicity to achieve safe, reliable operation.

Additional hardware complexity should be avoided where increased operator understanding can achieve a comparable net gain in safety.

4. Question:

Should the NRC develop general design criteria for advanced reactors by modifying the existing regulations, which were developed for the current generation of light water reactors, or by developing a new set of general design criteria applicable to specific concepts which are brought before the Commission?

Response

A new set of design criteria should be established for each advanced concept through the cooperative involvement of the NRC and industry A as the concept evolves. These criteria should emphasize a philosophy W of achieving acceptable risk rather than additional safety at any

cost, and, as

such, could be significantly different in format and content than the GDC's currently in 10CFR50.

9 5. Question: Should primary multiple and cost the NRC favor advanced reactor designs that concentrate the safety functions in very few large systems (rather than in subsystems), thereby minimizing the need for complex benefit balancing in the engineering of safe reactors?

Response

Commission's role to favor, a priori, a It is the Commission's responsibility to a proposed design provides the necessary No. It should not be the particular design approach. determine whether or not elements to protect the public health and safety. That would 4

establish the licensability of a design. Whether or not a license is granted will

depend, of course, on other factors, including the standardization policy.

Included in the Commission's selection criteria for choosing a particular standardized plant design would, presumably, be such factors as the level of confidence that a design goal for safety had been achieved and the ease with which regulatory decisions could be made. Since only standardized designs are to be considered, the "complex benefit and cost balancing in the engineering of the reactor" are clearly outside of the purview of the NRC -- which is "precluded from designing reactors for the purpose of establishing or developing their commercial potential." If non-standardized designs are to be permitted, then this objection would not apply.

6. Question:

What degree of proof would be sufficient for the NRC to find that a new design is based on technology which is either proven or can be demonstrated by a satisfactory technology development program? For

example, is it necessary or advisable to require a prototypical demonstration of an advanced reactor concept prior to final licensing of a commercial facility?

Response

The term "proof" is not appropriate. The Commission must determine, before granting a final license, that the public health and safety are adequately assured -- a much more reasonable standard. Demonstration of a concept as an additional requirement for advanced reactors needs to be considered in the context of a review of a specific design. However, a demonstration by prototype test should A be acknowledged as a possible alternative means of licensing, which could allow the use of more realistic, rather than conservative, commercial plant limits. 5

GA Technologies Inc. P.O. BOX 81608 SAN DIEGO, CALIFORNIA 92138 (619) 455-3000 Secretary of the Commission GA Technologies U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Docketing and Service Branch May 24, 1985 06lKETEl1 us~rnc

• ss MAY 28 A11 :18 GFFIC~,J: SE Cf~t. 1~ *,.

DOCKETING & SEf~ !Cf. BRANCH

Subject:

Proposed Policy for Regulation of Advanced Nuclear Power Plants Gentlemen: The subject policy statement provides welcome recognition of many issues relevant to the regulation of advanced nuclear power plants. GA Technologies supports the major thrusts of this proposal. We endorse the Commission's stated intent of improving the licensing environment for advanced reactors in order to "minimize complexity and add stability and predictability" in their regulatory process. We further support the NRC's definition of advanced reactors as "reactor designs which are significantly different from present generation light water reactors." Finally, we agree with the Commission that early interaction between the designer and the NRC Reactor Group would be advantageous. The primary shortcoming GA sees in the proposed statement is its tendency to mix policy with discussion of desirable advanced reactors design features. GA believes that the policy would be more effective if it emphasized high level policy guidelines. Specifically, GA recommends that the NRC's advanced reactor policy should:

1)

Explicitly recognize that, while advanced reactors should strive for and provide increased safety margins, the minimum degree of safety required should be the same as that required of existing licensed plants;

2)

Recognize that any safety margin beyond that minimum required level should, if provided, accrue compensating benefits 1n the licensing process;

3)

Acknowledge that supportive criteria should be directly responsive to top level goals specified for all plants.

4)

Reaffirm the NRC commitment to early review of advanced reactor concepts prior to a formal license application.

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- Specific comments in response to the questions raised by the Commission are attached. Thank you for this opportunity to comment on this significant proposed policy statement. Sincerely, ~'-th~u,1;p'#Ur-General Manager Power Reactor Programs

Attachment Comments on Questions Identified by the Commission Question 1 Should NRC's regulatory approach be revised to reduce dependence on prescriptive regulations and, instead, establish less prescriptive design objectives, such as performance standards? If so, in what aspects of nuclear power plant design (for example, reactor core power density, reactor core heat removal, containment, and siting) might the performance standards approach be applied most effectively? How could implementation of these performance standards be verified? Response to Question Prescriptive regulations can exact a heavy penalty in terms of discouraging innovation and obscuring what is really to be achieved (i.e., protection of the public's health and safety). GA recommends that, instead of relying on prescriptive regulations, the Commission adopt quantified, measurable dose/risk goals which provide the bases for judging reactor licensability. Verification of compliance could be accomplished through risk assessment analyses, tests, and/or any combination of appropriate analytical or demonstration techniques. If performance standards are chosen as a method of verifying goal compliance, they should be applied only to those aspects of the design which are necessary to meeting the goals described above. Since various concepts are likely to choose different approaches to meeting this goal, it would be expected that the application of performance criteria would remain design specific. GA does not support the premature imposition of standards that may unnecessarily restrict the design approach used by presupposing what may be important for the safety of advanced concepts. Question 2 Should the regulations for advanced reactors require more inherent safety margin in their design? If so, should the emphasis be on providing features that permit more time for operator response to off-normal conditions, or should the emphasis be on providing systems that are capable of functioning under conditions that exceed the design basis? Response to Question 2 The regulations should not require more margin in the design. However, GA believes that advanced reactor designers should strive for more passive safety in their designs. We believe that to the extent advanced reactor designers provide features, such as long response times or other margins, they should be given credit for this in the development of a safe yet cost effective design. That is to say, the safety margin provided by these types of features should be recognized and accrue some compensating benefit within the licensing process such that the designer has the flexibility to seek designs that may not otherwise have been allowed. The sort of benefits which GA would expect

to see include fewer required safety class systems, substantial modification of the requirement for containment and exemption from the need for offsite sheltering and evacuation. We further believe that such designs should be more easily licensed to the extent that passive safety margins simplify the task of demonstrating compliance with quantitative safety goals as described above in response to Question 1. Question 3 Should licensing regulations for advanced reactors mandate simplified designs which require the fewest operator actions, and the minimum number of components needed for achieving and maintain safe shutdown conditions, thereby facilitating operator comprehension and reliable system function for off-normal conditions? Response to Question 3 The NRC should avoid the type of design prescriptive regulation suggested in Question 3. As in the answer to Question 2, regulations should be kept directly responsive to safety goals. GA does not support regulations which mandate the means by which these goals are to be achieved. The designer should be left free to optimize (or balance) his design so long as goals are met. Question 4 Should the NRC develop general design criteria for advanced reactors by modifying the existing regulations, which were developed for the current generation of light water reactors, or by developing a new set of general design criteria applicable to specific concepts which are brought before the Commission? Response to Question 4 The NRC should not modify the existing LWR regulations for use in advanced reactor reviews but should instead develop a new set. The current GDC are excessively design prescriptive with no clear traceability to the higher level safety goal of protecting the public health and safety. We would support a complete review of the General Design Criteria leading to revision in not only their content but also their structure, such that they become directly responsive to a quantified dose/risk goal as described above. Question 5 Should the NRC favor advanced reactor designs that concentrate the primary safety functions in very few large systems (rather than in multiple subsystems), thereby minimizing the need for complex benefit and cost balancing in the engineering of safe reactors?

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Response to Question 5 The NRC should not favor any particular reactor characteristics as an end in themselves. Rather, they should be evaluating all reactor concepts against the quantitative safety goals that are aimed at protecting the public. If certain features allow a particular reactor to meet these goals with greater margin or greater certainty the NRC should view this with favor and should allow credit to be given for this in the licensing process. This credit or compensating benefit is discussed further in the response to Question 2. Question 6 What degree of proof would be sufficient for the NRC to find that a new design is based on technology which is either proven or can be demonstrated by a satisfactory technology development program? For example, is it necessary or advisable to require a prototypical demonstration of an advanced reactor concept prior to final licensing of a commercial facility? Response to Question 6 There is an extensive base of regulatory precedence regarding the level of data required to substantiate compliance with regulatory requirements. For example, the prioritization and resolution of the NRC's unresolved issues gives evidence to methods within the NRC for judging what constitutes a sufficient "degree of proof." Component and systems-level testing of certain advanced features might be required but should be considered on a case-by-case bases, dependent upon the design. However, GA does not believe that it is necessary or desirable to create a blanket requirement for plant-level prototypical demonstrations for advanced reactor concepts.

r OAK RIDGE NATIONAL LABORATORY POST OFFICE BOX X OPERATED BY MARTIN MARIETTA ENERGY SYSTEMS, INC. Secretary of the c.ommission U.S. Nuclear Regulatory Conmission Washington, D.C. 20555 Attention: Docketing and Service Branch Gentlenen: OAK RIOGE, TENNESSEE 37831 May 24, 1985 DIC.:KETED USNRC 135 HAY 28 All :14 GFFJ E OF SECR[TA;; Y DOCKETING &. srnv1c( BRANCH Comnents on the u.s. Nuclear Regulatory Conmission's 10 CFR Part 50, "Proµ>sed Policy for Regulation of Advanced Nuclear Power Plants," by The oak Ridge National Laboratory {FR Doc, 85-7136) In resµ>nse to the request for conments on the subject "Proµ>sed Policy for Regulation of Advanced Nuclear Power Plants," the oak Ridge National Laboratory sul:mits the enclosed comnents and reconmendations. Please call Don Trauger (FTS 626-6730) if you have questions or need additional inforrration. HP:js Enclosure cc: D. F. Bunch, OOE/HQ D. F. Giessing, OOE/HQ J. s. Herrington, OOE/HQ K. Jarmolow J. A. Umhard, OOE/ORO N. J. Palladino, NRC I. Spiewak, ORNL Consultant D. B. Trauger A. W. Trivelpiece, OOE/HQ File - RC s1[::~k Herman Postma Director MAY 2 9 1985 Ac1<Pl<M\\ed81d by card...... * * * * * * * *.-.

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CDMMENTS CN '!HE U.S. NUCT.FAR RffiULA'IORY CDMMISSION 10 CFR PART 50, "PROPOSED J?OLICY FOR RffiULATICN OF ADVANCED NUCLEAR rovER :a.ANTS," BY THE OAK RIIx;E NATIONAL LABCRA'IORY we conmend the proposed policy as an appropriate and helpful step toward the regulation of advanced reactors. Clarification of the licensing advantages and potential problems for simplified designs and passive safety features should be addressed early through informal review. Simplification of the licensing process while retaining full assurance of public safety is a desirable goal which should be under-taken with appropriate consultation by the NRC staff with the OOE staff and contractors, utility representatives, and the nuclear industry. We see the current effort by the advanced reactors group within Nuclear Reactor Regulation as an initial step toward these objectives. It is apparent that the design safety of reactors in the future can substantially exceed the NRC's proposed safety goals. Designs such as Sizewell-B or the advanced B'lR af6 likely to have predicted core melt probabilities of the order of 10 /year, 100 times better than the goal. Such a large margin of safety is desirable to cover uncertainties in the analysis, especially for reactors that depend on active safety systems. Reactors depending primarily on passive safety features are likely to be able to achieve oomparable or larger predicted safety margins. '!he industry also is likely to change for the better in respect to safety. We do not anticipate any weak utility organizations in the U.S. to undertake new reactor programs. The presence of the Institute of Nuclear Power Operations (INro) provides additional assurance that advanced reactors will be built and operated by competent entities. Given the current upgrading of nuclear plant technology and related factors, NRC's efforts to reduce prescriptiveness should find public and political acceptance. We believe these efforts should focus on the plant as a whole rather than on specific subsystems. Once a standard design is referenced for oonstruction, we could envision step-wise NRC review and approval of the siting, completed subsystems (civil-works, eguipnent supports, oontrols, primary cooling system, etc.), and of a staffing and operating plan. The granting of an operating license should be automatic if the plant systems are canpleted according to specification and the operating staff satisfies NRC (and INIO) criteria. In response to the questions posed, we offer the following corrments:

1. Should NRC' s regulatory approach be revised to reduce dependence on prescriptive regulations and, instead, estab-lish less prescriptive design objectives, such as performance standards? If so, in what aspects of nuclear power plant design (for example, reactor oore power density, reactor oore

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Response

NRC should maintain adoption of less prescriptive regulations as a long-term goal. Suitable J;erforrnance standards are preferred to prescriptive design objectives for the following reasons:

a. '!be industry is familiar with designing to standards.

b.

In general, J:erforrnance standards allow nore flexibility in design. This can be very important to safety, where the combination of oomponent systems into an overall nuclear plant design must be closely coordinated. '!be responsibil-ity to achieve this integration is placed on the designer rather than the regulator.

c. Standards have served well in protecting the public for many industries.

Performance standards should be applied to essentially all asJ;ects of the nuclear steam system design and should extend to all safety-related systems which determine the safety of the public. Achieving such a goal requires improvement in reactors and in the industry, as well as structural changes in NRC. It is most likely that such a goal could be achieved in steps. Several kinds of step:3 can be envisioned:

a. Adoption of passive safety systems to replace or supplement active safety systems. '!be use of passive systems makes verification simpler in that safety becomes more deterministic and less probabilistic.

b. Performance standards can be applied to the plant's response to certain accident initiators such as an earth-quake of a SJ;ecified intensity, or a particular piJ;e break.

A combination of test and analysis can then be used to determine that a severe accident will not result.

c.

As eXJ;erience is gained with the awlication of J;erforrnance standards of limited SOOJ:e and in the use of probabilistic risk assessment, greater weight can be placed on the use of PRA to verify the achievement of safety goals on an overall basis.

d. '!be response of plants to actual challenges to safety systems (Licensee Event Reports) can be analyzed to verify that the PRA is soundly based.

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3 To the extent :p:>ssible, performance standards should be supplemented by standards provided by technical. societies and other standards organizations. These would include materials, design, configuration, and other features to achieve both safety and standardization. Although standardization is not necessarily an NRC safety re::iuirernent, it must surely reduce the licensing effort and should be encouraged by the NRC policies.

2. Should the regulations for advanced reactors re::iuire more inherent safety margin in their design? If so, should the emphasis be on providing features that permit more time for operator res:p:>nse to off-normal conditions, or should the emphasis be on providing systems that are capable of functioning under conditions that exceed the design basis?

Reswnse It is self-evident that inherent or p:issive safety, additional time for operator action, and wide margins of capability beyond design are desirable for safety. Unfortunately, each of these involves tradeoffs in performance and cost. 'Ihese features should be encouraged but not re::iuired and should be viewed as mechanisms for meeting the performance re::iuirements of the standards referred to in Question No. 1.

3. Should licensing regulations for advanced reactors mandate simplified designs which re::iuire the fewest operator actions and the minimtJn number of can:p:>nents needed for achieving and maintaining safe shutdown conditions, thereby facilitating operator canprehension and reliable system function for off-normal conditions?

Res:i;x::>nse We believe that simpler designs are likely to make safety 100re predictable and verifiable and reduce burdens on both the operator and the regulator. NRC should therefore encourage but not re::iuire simplicity. Facilities to enhance operator comprehension and understanding and to achieve reliable system functions for both normal and off-normal conditions should be re::iuired. However, these may be achieved by the simplification of design to re::iuire fewer operator actions or, for example, by providing the operator with automated assistance, improved information display, and more extensive analytical systems.

4. Should the NRC develop general design criteria for advanced reactors by modifying the existing regulations, which were developed for the current generation of light water reactors,

4 or by developing a new set of general design criteria applicable to specific concepts which are brought before the Conmission?

Response

General design criteria should not be modified until it is clear that the industry wishes to build plants of a new type. Frequent hearings on the subject would tend to reduce public confidence in the NRC's objectivity. Once it has been established that there will be advanced reactors of a type substantially different from I.WRs, it would be desirable and ar.propriate to develop a set of criteria for that reactor type. However, it would be prudent to develop preliminary plans and concepts for licensing concurrently with the corresi;x:>nding state of developnent for advanced reactors. This could be beneficial both to regulators and designers.

5. Should the NRC favor advanced reactor designs that concentrate the primary safety functions in very few large systems (rather than in multiple subsystems), thereby minimizing the need for complex benefit and cost balancing in the engireering of safe reactors?

Response

We believe that concentrating primary safety functions in a few large systems is likely to make safety more predictable and verifiable. However, the principle of redundancy has served well and must be sufficient to meet all requirements.

6. What degree of proof would be sufficient for the NRC to find that a new design is based on technology which is either proven or can be demonstrated by a satisfactory techmlogy developnent program? For example, is it necessary or advisable to require a prototypical demonstration of an advanced reactor concept prior to final licensing of a corrmercial facility?

Response

It is necessary that all safety design features be supi;x:>rted by analysis which has been validated by experimentation and testing. To the extent that such validation can be achieved in a prototype or demonstration reactor, this is obviously desirable. '!be prototype reactor mt only provides for the demonstration, but also the opi;x:>rtunity for discovering inadequacies or inconsistencies in the design or construction practices. However, many off-design features cannot be tested economically (or even safely) in a demonstration reactor. For example, there is no wey to subject a demonstration reactor to natural disasters such as seismic events, and it certainly would not be subjected to fire, to sabotage, or to the impact of an

5 aircraft crash. However, many features, such as the total loss of off-site p<:Mer and modest off-design conditions, can be included in the test program of a demonstration reactor. May 16, 1985

uoraJ IUlll£R PR .,_-!Jo CS?J F~ J/BSZ 0 Public Service Public Service Company of Colorado 2420 W. 26th Avenue, Suite 1000, Denver, Colorado 80211 D CKETEO USNRC

• as HAY 28 All :16 Secretary of the Commission U. S. Nuclear Regulatory Commission Washington, DC 20555 Attn:

Docketing and Service Branch Gentlemen : Docket No. 50-267 May 24, 1985 Fort St. VraiOFFICE OF SE.CRUA1,, Unit No. 1 OOCKETING & srnv1/f P-85182 BRANCH

SUBJECT:

Comments on Proposed Policy for Regulation of Advanced Nuclear Power Plants (10 CFR Part 50) Public Service Company of Colorado (PSC) has reviewed the proposed Policy for Regulation of Advanced Nuclear Power Plants as published in the Federal Register (Vol. 50, No. 58, dated Tuesday, March 26, 1985) and has prepared responses to the six questions posed by the NRC. The responses are contained in the Attachment to this letter. As a general comment, PSC supports the Commission's 1985 Policy and Planning Guidance statement that encourages industry to pursue standardization of the current generation of nuclear power reactors. However, the immediate application of this policy to advanced nuclear reactors may be inappropriate, since advanced reactors, by definition, are reactor designs which are significantly different from the present generation of light water reactors and the various advanced reactor concepts ordinarily differ in many ways from one another. Until a particular advanced reactor develops into a proven design that is capable of giving rise to a new family of nuclear power

plants, it would be premature to think in terms of standardization for such units.

I u. s. NUCLEt,R REGULATORY C0MMISS/Ot,( OF

- If there are any questions, please contact Mr. M. H. Holmes at (303) 571-8409. HLB/SLG:pa Att achment Very truly yours, C}n,C)J~ A __ H. L. Brey, Manager F Nuclear Licensing & Fuels Division

Responses to Questions Attachment to P-85182 Question 1 - The NRC should be mindful that the regulatory approach adopted for advanced reactors should have, as a primary goal, the encouragement of design innovation and creativity. By reducing its dependence upon prescriptive regulations for advanced reactors, the NRC would be taking a positive step in furtherance of that objective. Even the imposition of performance standards should be considered carefully since they too could impose sufficient restrictions on the industry to where they have a counter-productive impact on advanced reactor design. The use of prescriptive regulations and performance standards should be held to a minimum (1) as long as the NRC is kept informed of new design concepts that are under consideration by the nuclear

industry, (2) as long as prospective applicants have the responsibility for supporting confirmatory research and for providing technical evidence of the feasibility and safety of new design concepts and (3) as long as the NRC develops the capability for timely, appropriate assessment and response to innovative and advanced designs presented for review.

Any performance standards established for advanced reactors should be drafted in such a way that they are capable of being implemented and verified without the need for subjective i nterpretation. Question 2 It is the NRC's responsibility to assure adequate protection of the public health and safety in connection with all nuclear power plants. If a particular level of safety is deemed adequate by the NRC for the light water reactors, it would appear to be inconsistent and even discriminatory for the NRC to mandate more inherent safety margin in the design of advanced reactors. The NRC requires a prospective applicant for an advanced reactor to identify and solve technical problems, to support confirmatory research on new design concepts and to provide sufficient evidence that a particular new design concept incorporates fundamental safety characteristics. PSC believes that each situation involving an advanced reactor should be judged on its own merits. Since light water reactors as well as various advanced reactor designs react differently to off-normal conditions, the NRC should reorganize such distinctions and avoid slavishly mandating the same amount of time for operator response to off-normal conditions. Otherwise, there would be no incentive for industry to develop advanced reactors with inherent safety characteristics. Question 3 - PSC believes that licensing regulations issued by the NRC should avoid mandating any aspect of the advanced reactor design. This PSC position is consistent with the NRC's proposed policy of avoiding the placement of unnecessary constraints on

Attachment to P-85182 the development of new design concepts. The term simplified designs" can hardly be applied with accuracy to any nuclear reactor, whether it be a light water reactor or an advanced reactor, except in a relative connotation. This comment is especially relevant in those cases where the defense-in-depth design concept has to be utilized. The proposed language (simplified designs, fewest operator actions, minimum number of components) is highly subjective and subject to interpretation even if some reference standard could be established with which a proposed design could be compared. It would seem that economic considerations would prompt industry to achieve these design objectives on its own. Question 4 It has been PSC's experience that design criteria and regulations developed primarily for the current generation of light water reactors have been difficult to apply to an advanced reactor such as PSC's Fort St. Vrain power plant. Rather than modifying existing regulations to reflect advanced reactor concepts, PSC believes that it would be better to develop a new set of general design criteria and regulations for specific advanced reactor concepts. For best results, this kind of effort should be undertaken in the form of a joint NRG/Industry collaboration as is typically done in the case of codes and standards. Question 5 - PSC believes that the NRC should not concern itself with alternate design concepts when the issue involves choosing between two designs in order to minimize the need for complex benefit and cost balancing in the engineering of safe reactors. The term favoring" one design over another i s meaningless unless the NRC is prepared to mandate advanced reactor designs that concentrate the primary safety functions in very few large systems rather than in multiple subsystems. For the NRC to mandate one design concept over another for essentially economic reasons would be contrary to the NRC's proposed policy of avoiding the placement of unnecessary constraints on the development of new design concepts (See Question 3). Question 6 - As long as an applicant is able to satisfy the NRC that a new design is based on technology which is ei t her proven or can be demonstrated by a satisfactory technology development program, it should not be necessary for the NRC to require a prototypical demonstration of an advanced reactor concept prior to final licensing of a commercial facility. If, for reasons of economic

prudence, an applicant deems it advisable to proceed with a prototypical demonstration of an advanced concept, that decision should rest solely with t he applicant.

Department of Energy Washington, D.C. 20585 Mr. Samuel J. Chilk Secretary of the Commission Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Ch il k:

0 CKETEO USNRC '85 MAY 24 PS :15 GFFl"E Or SEC *1*.TA, OOCK THl tv SET ! :.. BRAt4C!I May 24, 1985 This letter provides the Department of Energy's comments on the Nuclear Regulatory Commission's (NRC) proposed policy statement regarding regulation of advanced nuclear powerplants as published in Federal Register on March 26, 1985. The answers to questions posed in that statement are provided in the enclosure. The Department considers that it is critically important to improve the efficiency of the nuclear licensing and regulatory process and has had introduced into both Houses of Congress the "Nuclear Facility Standardization Act of 1985 11 to accomplish that objective. Any policy statement on the regulation of advanced reactors should be supplementary and complementary to that prime objective. Within the above context, the Department endorses the Commission's intent to establish a basis for evaluating the technical merits of safety provided by the design features of advanced reactors and to develop an efficient licensing environment for these powerplants. We believe the development of regulations for advanced reactors that are truly less prescriptive and that rely more upon top level criteria and standards will constitute a major accomplishment. The policy statement should provide for the establishment of regulations for advanced reactors that encourage maximum flexibility in design approaches to meet safety criteria. The development of these criteria should provide standards that are easily measured to determine if criteria have been met. Our agreement with these objectives is demonstrated by the emphasis we have been placing in our advanced reactor program to develop advanced designs that are reliable, economic, and meet safety requirements in a more demonstrable fashion. As part of our effort to achieve this objective, we are emphasizing utilization of innovative, and state-of-the-art technology to develop simplified standardized designs that include passive safety features. We expect that these efforts and NRC's policy for these powerplants will result in a less controversial and more efficient licensing process and minimized licensing costs. Accordingly, we support the issuance of a policy statement on the topic of regulation of advanced reactors. The proposed policy statement should be

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2 revised to make clear that the Commission intends to minimize the application of prescriptive regulations to licensing of advanced reactors and to eliminate the prescriptive design overtones that the present policy statement contains. The proposed policy should provide a clear statement encouraging the development of advanced reactors with the general characteristics described above but should not identify specific design solutions or features. Also, the revised statement should continue to limit the application of this policy to advanced reactors and specifically exclude concepts such as the final designs for evolutionary light water concepts currently being developed by commercial reactor vendors. Moreover, the policy statement should make clear that any standards that are evolved during the development of advanced reactors should not be applied in a backfit mode to existing powerplant designs. Also, the criteria for advanced reactor plants need not and should not be more strict than the criteria for current powerplants. Although it is anticipated that advanced reactors will achieve balanced improvements in economics and safety through design simplification, inclusion of passive features in these designs and improvements in the regulatory process, we do not believe that there is a basis to impose stricter criteria on these concepts. We also endorse the Commission's proposed policy to encourage interactions among NRC, the Department, and the industry to review new designs at an early stage of development. We believe the establishment of an advanced reactor group within the NRC to function as the focal point for these interactions was appropriate and has been extremely helpful in our ongoing efforts. Accordingly, we have been working with the NRC staff to develop plans and schedules for early discussion and review of the advanced reactor designs sponsored by the Department. We believe that this process is the best means for evaluating the design features important to the regulation of advanced reactors. We anticipate that the advanced reactor group will be vested with the resources and authority to conduct the necessary interactions and make recommendations to the Commission regarding the acceptability and licensability of advanced designs.

3 We look forward to your continued cooperation and assistance in the review of advanced reactors and would be pleased to respond in more detail should the need arise. Enclosure cc: Chairman, N. Palladino, NRC Commissioner J. Asselstine, NRC Commissioner F. Bernthal, NRC Commissioner T. Roberts, NRC Commissioner L. Zech, NRC Executive Director for Operations, W. Dircks, NRC Sincerely, ~u/41-,cj James W. Vaughan, Jr. Acting Assistant Secretary for Nuclear Energy

Enclosure Department of Energy Comments and Answers to Questions Posed in the Proposed Policy Statement for Regulation of Advanced Reactors Issued by the Nuclear Regulatory Commission (NRC) in the Federal Register on March 26, 1985 General

1.

The scope of the proposed policy statement is appropriate. The proposed policy statement dealing with regulation of advanced nuclear powerplants should be viewed as one of several mechanisms for internally reforming the administrative process of nuclear reactor regulation governing plants for which construction permit applications have not been submitted.

2.

The policy statement focuses on prescribing design features as the means to improve the efficiency of the licensing process and does not address the critical importance of rationalizing the administrative regulatory process itself. We believe that if the policy statement is not consistent with actions such as those contained in our proposed licensing reform legislation, investment risks of new powerplants may not be acceptable.

3. A range of policy approaches exist; some policy approaches may be well suited to the regulation of some reactor concepts but cause undue hardship for others.

We recognize that you have considered a number of options before selecting the approach in the proposed policy statement. We believe that our comments and responses to your questions may lead you to consider alternate approaches. Presented below are some such viable alternatives: o Regulatory requirements that eliminate whole classes of candidate concepts, such as requirements that any new reactor employ passive safety systems (the proposed policy statement would seem to be of this form). o Process improvements only (backfit reform, standardization, Standard Review Plan updating); probably best suited for improved or evolutionary adaptations of operating Light Water Reactors (LWR's) and not recommended for the kind of reactors considered under the proposed policy statement. o Process improvements together with incentives to develop designs which would make compliance with NRC requirements easier, or give greater public assurance that severe accidents would have relatively benign consequences. o An additional set of requirements for new designs such as a requirement to demonstrate compliance by system performance tests (moving away from the demonstrate-by-analysis approach associated with current requirements and designs).

2 o A fundamental restructuring of the regulatory process for new reactors. For example, if the intent is to develop the framework for applications in the mid-1990's, a top-down approach could be employed, based on safety goals and PRA; a move away from deterministic criteria and new procedures based on risk based criteria or performance based criteria could be the basis for a new approach. The evident shortcomings of the present system strongly support the use of top level criteria, implemented through a predictable, well defined review process. Absent some showing of significant disadvantage of such an approach for advanced reactors, the Department recommends that the Commission move in this direction. Res onses to the uestions Posed in NRC Polic Statement for Re ulation of Advanced Nuc ear Powerplants NRC Question Number 1 Should NRC's regulatory approach be revised to reduce dependence on prescriptive regulations and, instead, establish less prescriptive design objectives, such as performance standards? If so, in what aspects of nuclear powerplant design (for example, reactor core power density, reactor core heat removal, containment, and siting) might the performance standards approach be applied most effectively? How could the implementation of these performance standards be verified? DOE Response: NRC's regulatory approach should be revised to reduce dependence on regulations that effectively prescribe design features. Unless this is changed, implementation of the policy will exact a heavy penalty, both in terms of discouraging innovation and in terms of limiting the applicants' flexibility in seeking a balanced approach to safety. Less prescriptive design objectives, including approaches which start from the specification of top level safety criteria, should be a useful alternative to existing practices, and their use will require definition of criteria, and acceptable methodologies for showing compliance with such criteria. Accordingly, we recommend that the Commission's regulatory approach consist of:

1. establishing top level safety criteria.

2.

establishing a predictable, well defined regulatory process. This well defined regulatory process should identify the information that will be required by NRC and the methodology it will use to evaluate this information to determine if the top level criteria have been satisfied. In turn, the designer, constructor and operator should be provided the flexibility to propose the approaches and requirements that each of these respective institutions will use to satisfy both the top level safety criteria and economic requirements. These institutions should also be provided the flexibility to propose standards or lower level criteria that will be used with the above prescribed methodology to determine if design requirements have been met. Each institution should also be provided the

3 flexibility to propose the combination of tests, analysis, and standards developed by recognized technical societies, etc. that the institution will utilize to provide sufficient confidence that the safety criteria will be met. This approach should also facilitate the ability of the public and others to follow and thus concur with decisions and actions taken by NRC and the owner operator throughout the design, construction and operation of these powerplants. This understanding is mandatory for optimizing the efficiency of the licensing process and optimizing the ability of the design, construction, and operation to meet the safety criteria in a cost effective manner. We recognize that the implementation of this approach will not be simple and we recommend that the policy statement provide for early interactions between NRC and the Department's advanced reactor program to remove obstacles to the implementation of this approach. NRC Question Number 2 Should the regulations for advanced reactors require more inherent safety margin in their design? If so, should the emphasis be on providing features that permit more time for operator response to off-normal conditions, or should the emphasis be on providing systems that are capable of functioning under conditions that exceed the design basis? DOE Response: No. The regulations for advanced reactors should provide flexibility in the design approach to meet the basic safety requirements. The proposed policy statement encourages "more inherent safety margin". That term is undefined and susceptible to varying interpretations. There is no fundamental reason for requiring stricter criteria than applied to current generation LWR's. In any event, before any attempt is made to encourage use of systems that permit more time for operator response to off-normal condition or systems that are capable of functioning under conditions that exceed the design basis, any benefit of such requirements should be weighed against other overall changes in plant investment risk or health risks and other important factors such as system complexity, constructibility and maintainability. NRC Question Number 3 Should licensing regulations for advanced reactors mandate simplified designs which require the fewest operator actions, and the minimum number of components needed for achieving and maintaining safe shutdown conditions, thereby facilitating operator comprehension and reliable system function for off normal conditions? DOE Response: We believe that the NRC should not mandate design simplification. Clearly, system choices that facilitate operator comprehension and reliable functions should be encouraged. However, the designers should have the flexibility to strike a balance between those features that provide greater

time for operator action against impacts on plant economics so long as safety goals are met. NRC Question Number 4 Should the NRC develop general design criteria for advanced reactors by modifying the existing regulations, which were developed for the current generation of light water reactors, or by developing a new set of general design criteria applicable to specific concepts which are brought before the Commission? DOE Response: 4 We believe a set of design criteria should be established for each class of advanced reactor concepts. We also believe these criteria should be developed as part of interactions between NRC and each of the Department's advanced reactor programs during the development of the individual concepts, and should reflect the unique features and characteristics of those concepts. NRC Question Number 5 Should the NRC favor advanced reactor designs that concentrate the primary safety functions in very few large systems (rather than in multiple subsystems), thereby minimizing the need for complex benefit and cost balancing in the engineering of safe reactors? DOE Response: We do not believe that NRC should favor any specific advanced reactor design features or approaches. NRC Question Number 6 What degree of proof would be sufficient for the NRC to find that a new design is based on technology which is either proven or can be demonstrated by a satisfactory technology development program? For example, is it necessary or advisable to require a prototypical demonstration of an advanced reactor concept prior to final licensing of a commercial facility? DOE Response: There is an extensive base of regulatory precedence on the level of data required to substantiate compliance with regulatory requirements. Demonstration of a concept as an additional licensing requirement for new reactors, or as a substitute requirement, needs to be considered in the context of a review of a specific design. Therefore, full scale testing of a prototypical reactor or major subsystem thereof, should not be a requirement, per se, but maybe a permissible alternative.

U:P YANKEE ATOMIC ELECTRIC COMPANY(.~F~,~,~ 9.e/ephone (617) 872-8100 TWX 710-380-7619

• GLA 85-*59 1671 Worcester Road, Framingham, Massachusetts 01701 May 23, 1985 FYC 07 DOCKETED USNRC Secretary of the Commission "85 HAY 24 All :16 United States Nuclear Regulatory Commission Washington, DC 20555 CFFICE Or SECf<E TARY DOCKETING & SE~'\\IICf BRANCH Attention:

Dear Sir:

Docketing and Service Branch Comments Pertaining to the Proposed Policy for Regulation of Advance Nuclear Power Plants (50FR11882, March 26, 1985) Yankee Atomic Electric Company appreciates the opportunity to comment on the proposed policy statement. Yankee Atomic owns and operates a nuclear power plant in Rowe, Massachusetts. Our Nuclear Services Division also provides engineering and licensing services for other nuclear power plants in the northeast including Vermont Yankee, Maine Yankee, and Seabrook. Yankee Atomic supports the Commission's dual goals of encouraging early interaction between government and industry and minimizing complexity and uncertainty in the regulatory process with regard to advance reactors. The Commission believes that simplicity of design is a desirable characteristic. We agree. We note with great pride that such a concept has been demonstrated to be safe and reliable at our Yankee plant, which is celebrating its 25th year of operation. The proposed policy statement queries whether advance reactor designs ought to seek enhanced or increased margins of safety. The public safety record of current reactor designs is outstanding. We think the proper objective of future designs should be to obtain comparable levels of safety in a simpler and more easily demonstrable fashion. When read in light of its legislative background, the breadth of the proposed policy is unclear to us. In order to avoid impacting reactors which are currently operating or under construction, we suggest that the policy statement be revised to clearly state that it pertains only to "different reactor designs" such as Pius, HTGR and the ongoing EPRI effort, and not to safety systems to be incorporated into reactors of current design. We have developed several other comments which address details of the proposed policy including responses to the six specific questions posed by the Commission, and present these in the attachment to this letter. MJH/mep Attachment Very truly yours, &a!.~ D. W. Edwards Director of Industry Affairs by

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ATTACHMENT TO FYC-85-07 Additional Comments of Yankee Atomic Electric Company Page 1 of 2 on Proposed Policy for Regulation of Advance Nuclear Power Plants I. Comments on Summary of Proposed Policy Statement 0 The summary includes the statement, "[s]ince the wealth of analyses, research, development and operating experience provide useful insight to designers, it is also expected these reactor plants will have an enhanced margin of safety". If this statement is intended to imply that future reactor designs will be required to meet stricter safety criteria than current generation designs, we disagree. The actual public safety record of existing nuclear power plants to date has been an unprecedented success. The objective of future designs should be to attain comparable levels of performance in a simpler and more demonstrable fashion. o The summary also states that "[i]t is anticipated that these designs will reflect the benefits of significant research and development work, and include the experience gained in operating the many power and developmental reactors both in the United States and throughout the world". In order for the designs to reflect experience from outside the United States, it will be necessary for the NRC to obtain and accept data generated in other countries. Thus the policy should include a statement to the effect that the NRC will actively pursue the development of mechanisms for the timely and effective incorporation of data from other countries into the licensing process. II. Answers to Questions posed in Proposed Policy Statement

1.

Question Number 1 asked whether performance standards or prescriptive regulations should be used by NRC. The use of performance standards in lieu of prescriptive regulations is strongly favored. Further, to maximize the effectiveness of regulation in protecting the public, the performance standards should be focused on and limited to those aspects of design and operation that are clearly related to mechanisms for the exposure of the general public to high levels of radiation. The early involvement of the NRC in the review of the design coupled with an emphasis on standardization should preclude the need for specification of relatively detailed design considerations.

2.

Question Number 2 concerns safety margins. The inquiry "[s]hould the regulations for advanced reactors require more inherent safety margin in their design" is sufficiently ambiguous when comparing widely differing concepts as to be of little or no value in providing guidance to the designer. In addition, as stated above, the performance of operating nuclear power plants to date is exemplary from the standpoint of public safety. Thus, the emphasi s for future reactor designs should be on simplicity and demonstrability of safety features. We see no justification for an arbitrary requirement of "more inherent safety margin".

Attachment to FYC 07 Page 2 of 2

3.

Question Number 3 asked what regulations should be mandated in order to achieve and maintain safe shutdown conditions. The primary issue here is the definition of "safe shutdown conditions". The policy should foster a concept specific evaluation of safe shutdown conditions, keeping in mind that the closer these conditions are to normal operating conditions, the simpler the systems and actions required to achieve safe shutdown will be.

4.

By question Number 4, the NRC asked if advance reactor design criteria should be based on existing regulations. A new set of general design criteria should be established for each advanced concept. Detailed criteria should be developed by the cooperative involvement of the NRC and industry as a concept evolves, subject to final approval by the NRC. The NRC should encourage industry initiatives to develop proposed design criteria.

5.

Question Number 5 asked if a few large systems should be encouraged over multiple subsystems. The NRC should encourage concepts which minimize the portion of the plant that has the potential to contribute to large releases of radioactive material. This would allow the safety review to focus effectively on the protection of the health and safety of the public. Questions with regard to tradeoffs between fewer large systems and multiple subsystems would be better left to the review of specific concept designs.

6.

Finally, question Number 6 concerned the degree of proof needed to determine that a concept design is based on demonstrable technology. The degree of proof required will be a function of the extent to which the concept design differs from designs for which extended operating experience is available and applicable. This issue will be strongly affected by the concept under consideration and the ability to factor in experience from other countries as discussed above. In considering this issue, it is helpful to separate proof of the concept design from the standpoint of public safety, from proof of the concept design from the standpoint of reliable and economic power generation. To the extent that safety issues can be limited to a small number of functions required of a few systems as discussed in our response to Question 5, a prototypical demonstration may not be required. However, it is reasonable to expect that the overall design of a power plant concept will evolve and improve during the course of design, construction, and operation of a demonstration plant, and that some of the changes may affect safety issues. To proceed to final licensing of a commercial facility without a prototype demonstration would require a determination by the NRC that only a very limited portion of the plant is safety related and subject to NRC review and approval.

EPRI Electric Power Research Institute May 23, 1985 Mr. Samuel J. Chilk Secretary of the Commission U. S. Nuclear Regulatory Commission Washington, D. c. 20555

• as HAY 24 A9:55

SUBJECT:

Comments on NRC Proposed Policy for Advanced Reactors

Dear Mr. Ch ilk:

The Electric Power Research Institute (EPRI) is pleased to provide general and specific comments on "Regulatory Policy for Advanced Reactors," (SECY-84-453A). The general EPRI comments are contained in the following paragraphs. The specific EPRI comments and responses to the questions contained in the subject policy are contained in Attachments 1 and 2, respectively. EPRI supports the issuance of a policy statement intended to improve the licensing environment for advanced reactors. EPRI believes that the NRC can, through the adoption of an effective policy, minimize complexity and add stability and predictability in the licensing and regulation of advanced reactors. Such a policy statement is necessary if nuclear power is to be a viable option for electric power generation in the near future. In addition to setting forth the gener-al design characteristics which contribute to more effective regulation, the policy statement should identify improve-ments in the regulatory process with the aim of achieving regulatory stabilization. As discussed in the February 7, 1985, Industry/EPRI Presen-tation to the Commission, EPRI has embarked on a major in-dustry program to develop detailed design requirements for advanced light water reactors with a prime objective of being economically competitive with other electrical genera-tion options. The goals of this program are generally con-sistent with the thrust of the Commission's proposed policy statement and the policy should unambiguously encompass this program. EPRI believes it is imperative that these requirements be developed in a stable licensing environment. Over the past three years, EPRI and the Industry have worked with the NRC staff to resolve current licensing issues applicable to Aoknowl *~by .* ~L.2.ff/.ff.: 3412 Hillview Avenue, Post Office Box 10412, Palo Alto, CA 94303 Telephone (415) 855-2000

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S, Chilk Page 2 advanced light water reactors. A methodology for identifi-cation, evaluation, and resolution of licensing issues has been developed which has been instrumental in closing a large number of issues potentially applicable to advanced light water reactors. A major redirection in the Commis-sion's policy to improve the licensing environment for all advanced reactors can have a substantial and constructive impact on the current EPRI/Industry program. To this end, Commission policy must establish overall safety requirements uniformly applicable to all advanced reactors, utilizing, for example, a safety goal such as is now under trial by NRC. But the policy must also recognize the different approaches that may be taken to develop advanced reactor designs. At this time there are two general ap-proaches to advanced reactor design, potentially requiring different detailed regulatory criteria within the overall common framework. These differing approaches are: (1) advanced reactor designs based on evolutionary improvements demonstrated by current light water reactor technology; and (2) advanced reactor designs based on substantial changes or radical departures from current technologies. The proposed policy statement should clearly accommodate each approach to advanced reactor design. Because of the available technology and the need to have a viable nuclear option available in the near future, the LWR evolutionary approach will require specific, unambiguous regulatory def-initions to assure regulatory stability. Such definition should include improvements in design criteria based on the large body of safety R&D data now available and on the ex-tensive LWR operating experience. It is our judgment that these improved definitions can be less prescriptive. For advanced reactor concepts incorporating a radical departure from current technology, more general guidance would seem appropriate initially to assure that unnecessary constraints are not placed on the development of new design concepts and in the longer run, to accomodate major technical departures in such advanced designs.

S. Chilk Page 3 EPRI welcomes the opportunity to provide comments on the proposed NRC policy on advanced reactors. I would be pleased to discuss our comments and the EPRI Advanced Light Water Reactor Program with NRC representatives at their convenience. Very truly yours, ,. 7.~ . Ta r Presi ent Nuclear Power JTT:bg

ATTACHMENT 1 The specific EPRI comments on "Regulatory Policy for Advanced Reactors," (SECY-84-453A) are as follows:

1.

With respect to the earliest possible NRC involvement, EPRI concurs with the Commission's proposed policy which encourages early and frequent communication with interested parties on the characteristics of a proposed advanced reac-tor design. Further, it is important to establish a stable and predictable licensing and regulatory process for advanc-ed reactors prior to the initiation of detail design. In this way, effective utilization of both industry and regula-tory resources can be achieved. Thus, emphasis must be placed on establishing, as soon as practicable, a stable regulatory framework that is more resistant to unnecessary change.

2.

With respect to desirable characteristics of advanced reactors, EPRI concurs with a design goal of a simpler and more reliable design with increased margins of safety which present less challenges to plant operators. However, it should be recognized that an advanced reactor design must achieve a balanced level of safety consistent with reliabil-ity and economic considerations to be a viable option. In developing advanced reactor design features to increase safety margins, all challenges to plant safety must be con-sidered and appropriate provisions made to assure that an acceptable level of safety is attained commensurate with the event consequences and probability.

3.

With respect to standardization, EPRI concurs that ad-vanced reactor designs should have the goal of a complete standardized design consistent with the practicalities of constructing a plant in an orderly and economical manner. Conceptual designs should be reviewed with the Commission as soon as practical to establish the fundamental plant charac-teristics that are to be used in the licensing process. Once fundamental plant characteristics or a standardized design is approved, in order to eliminate unnecessary plant changes, a specific pre-established backfit process should be established and followed.

4.

With respect to the NRC review of advanced reactors, EPRI recommends that for the evolutionary approach the cur-rent review process be followed to enhance the continuity of the review. The current reviewers are the ones most

familiar with current technology and b~st able to review plants based on this technology. To assure focussed atten-tion in implementing such a review, lead responsibility might be assigned to an advanced reactor review group to see that such reviews are obtained in a timely and in-depth manner. For advanced reactors based on radical design changes, an advanced reactor review group may well handle the entire review to assure that the development of new design and licensing criteria are accomplished in an effici-ent manner

• ATTACHMENT 2 The EPRI responses to the questions contained in "Regulatory Policy for Advanced Reactors," (SECY-84-453A) are as follows:

1.

The current regulatory process, with improvements, pro-vides a workable framework for the requirements for advanced reactors based on evolutionary approaches and can provide the basis for a stable regulatory environment. An innova-tive regulatory approach potentially adds too much uncer-tainty in the licensing process to be acceptable for reac-tors anticipated to be operational in the 1990's. EPRI believes that, in general, the current regulations are too prescriptive and in many cases overly conservative and recommends changes to current regulations to be applied to evolutionary advanced reactors based on the results of the major safety research results which NRC and the industry have obtained as well as from design, construction, and operating experience. Improvements in the current regula-tions should be considered in areas such as seismic criter-ia, piping integrity criteria, source term, emergency core cooling system criteria, quality assurance requirements, and technical specifications. Thus, EPRI recommends using the current regulatory process as the starting point for chang-ing current regulations in an evolutionary manner as a means of achieving a stable licensing process for the evolutionary advanced reactors. For advanced reactors based on radical design ap-proaches, the use of performance standards appears to be a practical approach. Because a substantially longer period is anticipated for the development of these design concepts, it appears that the performance standards can be developed based on preliminary information as it becomes available and consistent with the initiation of the detailed design pro-cess. The overall safety goal should be common to all reac-tors.

2.

EPRI believes that the Commission should encourage ad-vanced reactor designs with larger safety margins based on inherent reactor design and process features where appropri-ate. This would allow more emphasis to be placed on the man-machine interface rather than the current over emphasis on events that exceed the design basis. This should be accomplished by designs that provide longer operator res-ponse times, simplify operator response and minimize diag-nostic requirements. Further, advanced designs should be

based on best estimate, not conservative, analyses with a known quantifiable margin added at the end of the process. This analytical approach is necessary to assure a balanced design. In addition, once an acceptable margin of safety has been attained, changes which unnecessarily increase the safety margin should not be required if they affect the economic viability, reliability, or operability of the plant.

3.

Consistent with the EPRI program, EPRI recommends that the Commission should encourage designs which reduce opera-tor challenges and minimize plant complexity. Mandates tend to stifle the creativity necessary for an effective advanced design and should be avoided.

4.

As previously discussed, two types of reactor design approaches should be included in the policy statement: (1) evolutionary designs based on current technology; and (2) radical design approaches. For evolutionary designs, the current general design criteria should be employed except in cases where the current criteria have been demonstrated to be excessively conservative and changes can be justified. This approach will provide a more stabilized approach to licensing. For advanced reactors based on radical design changes, development of new criteria may be required to reflect novel design features. In either case, the final criteria should be established before the final design begins and should not be changed during the design and con-struction processes.

5.

Advanced reactor designs can only be judged on the basis of the total integrated plant design. Thus, it must be considered premature to prejudge the advanced designs that will be developed. Further, it must be demonstrated that an advanced design is economical, as well as safe, before it can be considered a viable concept. In general, as reflected in the EPRI program, EPRI believes that advanced designs should be based on a simpler and more reliable systems design approach which should be cost-effective.

6.

The need for a demonstration or prototypical facility is dependent on the magnitude of change introduced by the ad-vanced reactor design. For evolutionary approaches based on current technology, a demonstration facility should not be required because the basic design has previously been demon-strated. For advanced reactors based on radical design changes, it should be anticipated that a prototypical or demonstration facility will be required.

I n ~.::) EGC.G Ida ho. Inc. P.O. BOX 1625, IDAHO FALLS, IDAHO 83415 April 22, 1985 Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Docketing and Service Branch DOtKETEO USNRC

• as APR 30 All :18 EG&G IDAHO, INC. RESPONSE TO NUCLEAR REGULATORY COMMISSION'S REGULATORY POLICY FOR ADVANCED REACTORS (SECY-84-453A) - Zan-54-85

Dear Sirs:

In general, EG&G Idaho, Inc. believes that the referenced Nuclear Regulatory Commission (NRC) Regulatory Policy for Advanced Reactors provides the appropriate support and guidance, namely; 1) encouraging the earliest possible interaction between developers and the NRC, 2) encouraging complete standard plant designs, 3) providing general regulatory guidance designed to avoid unnecessary constraints at the conceptual design phase, 4) encouraging design features that will minimize complexity and uncertainty in the regulatory process, and 5) providing a receptive focal point within NRC for advanced reactor evaluations. Pertaining to the call for public comment contained in the NRC's letter SECY-84-453A EG&G Idaho has submitted, in Attachment A, responses to the questions asked relative to the Proposed Advanced Reactors Regulatory Policy. In addition, Attachment Bis forwarded for your consideration. Attachment B presents EG&G Idaho's recommendation as to a set of all encompassing national-perspective-driven requirements and goals for advanced reactor designs. Features that minimize complexity and uncertainty in the regulatory process are included within this broader context. We at EG&G Idaho are hopeful that the comments provided herein will be helpful to the NRC in their quest to develop a satisfactory policy - relative to the licensing of potential advanced reactor concepts. lk Attachments: Response to SECY-84-453A PPD-NT-84-001 Very truly yours,

• • MJC\\!Al 1t£GULAT0RY coMM1SSIOt4 DO@.tCETIHG & SatVKE SECT ION QfFKt OF THE SECRH h.RY Of 'THE COMMISSION Docu..... nt Stat is! ics ---

,. *** Oat* CopMIII Received / - ~d' I Copies P ced ~ ~ ~tt ~tPS,~W~ I

I Attachment A Page 1 of 3 INEL Response to Questions in SECY-84-453A Regulatory Policy for Advanced Reactors Q1. 1 Should NRC's regulatory approach be revised to reduce dependence on prescriptive regulations? A1. 1 It is the INEL's position that the nuclear industry could be enhanced, with no increase in public health risk, 1f the regulatory approach was one that reduced dependence on prescriptive regulations. Q1.2 Should NRC's regulatory approach be revised to establish less prescriptive design objectives, such as performance standards? A1.2 Perhaps. The regulatory approach should be based on some agreeable and defensible top level safety criteria that are based solely upon the protection of the health and safety of the public. If performance standards can be technically justified as the basis for regulatory policy then so be it. Q1.3 If rformance standard n out to be to des n ob*ective what n or exa le, reactor core va containment, and sitin formance standards a roach be applied most effective y. A1.3 The performance standards should not restrict or regulate the design approach used as long as the design can be satisfactorily shown to meet the top level safety requirements. For example, one concept might require containment to meet the top level radiological release criteria and therefore meeting top level requirements would require some demonstrated containment performance level established by the designer. Another concept may not need a containment to meet the top level radiological release criteria but only a highly reliable reactor core heat removal system. In this case the performance level of the reactor core heat removal system would need to be demonstrated. Ql.4 How could implementation of these performance standards be verified? A1.4 Performance verification tests prior to licensing the first plant and periodic testing during the normal design life of future plants would be the preferred mode.

I I Attachment A Page 2 of 3 Q2. 1 Should the regulations for advanced reactors require more inherent safety margin in their design? A2. 1 The concept of margin should only be addressed when satisfactory top

• level safety criteria have been established.

If the criteria are established to protect the health and safety of the public and the reactor concept is successfully safety tested to that criteria, then very little margin is necessary. The top level safety criteria, or safety performance standards, should be defined for all classes of operation and transients to a level that is acceptable and sufficiently defensible that no margins are required. This is especially true if the criteria are to be demonstratively tested. Q2.2 If more inherent safety margin in the design is required, should the emphasis be on providing features that permit more time for operator response to off-normal conditions, or should the emphasis be on providing systems that are capable of functioning under conditions that exceed the design basis? A2.2 The emphasis should be placed on features that permit more time for operator response. Q3. 1 Should licensing regulations for advanced reactors mandate simplified designs which require the fewest operator actions, and the minimum number of components needed for achieving and maintaining safe shutdown conditions, thereby facilitating operator comprehension and reliable system function for off-normal conditions? A3. 1 There is no doubt that keeping the designs simple will facilitate easier operator comprehension and probably safer facilities. However, the trade-off has always been, and will remain in the future, one which trades safety and ease of operation with plant availability. The point again is that once the top level safety criteria are established by the regulators, the designers should be free to perform these trades without interference, especially if the safety criteria are going to be satisfied demonstratively. Q4. 1 Should the NRC develop General Design Criteria for advanced reactors by modifying the existing regulations, which are developed for the current eneration of li ht water reactors orb develo in a new set o s app icab e to ic concepts which are brought before the Commissions?

I Attachment A Page 3 of 3 A4. 1 The General Design Criteria, the Design Basis Events, and the safety classification of Systems, Structures, and Components should all be developed based upon 1) the top level safety criteria for the protection of the health and safety of the public and 2) the specific concept that is under consideration. No doubt the existing light water criteria should be considered but the objective should be to develop criteria that are technically traceable only to the top level safety criteria and not necessarily to the existing LWR criteria. QS. 1 Should the NRG favor advanced ns that concentrate the functions in stems rather than in and cost a ancing in the engineering o safe reactors? AS.1 The NRG should not favor" any reactor design. The NRG should establish criteria which protect the health and safety of the public. If the top level criteria technically "favors" a particular set of features then so be it. Q6. 1 What degree of proof would be sufficient for the NRG to find that a new design is based on technology which is either proven or can be demonstrated by a satisfactory technology development program? For example, is it necessary or advisable to require a prototypical demonstration of an advanced reactor concept prior to final licensing of a commercial facility? A6. 1 For the first plant it is not only advisable but necessary to demonstrate the advanced reactor concept prior to final licensing of the first commercial facility. The demonstration should be relative to the top level safety criteria established by the regulators. The specific tests should not be prescriptive but agreed upon by the regulators and the applicant. Assuming that satisfactory safety testing is completed it should not be necessary to further test additional units as long as the applicants can show that the unit was designed, fabricated, and assembled using the specifications that were utilized for the tested unit.

I I I I.. 1 I I 1e I 1 n ~~EGC..G Idaho, Inc. Report No. _ P_P_D-_N_T-_8_4-_O_O_l __ DOCKETED USNRC 135 APR 30 All :18 OFF /CE o; SEC.at.,'. DOCKET ING & SERv1r f BRANCH Date: ___ F_eb_r_ua_r...::...y_l_9_8_5 __ INTERNAL TECHNICAL REPORT

Title:

REQUIREMENTS FOR NEW POWER REACTOR CONCEPTS Organization: NEW TECHNOLOGY DEVELOPMENT PROJECTS Author: S. A. Atkinson, P. W. Dickson, M. L. Griebenow, E. A. Harvego, and W. G. Lussie I Checked By: -~-~ ___.L_~ Approved By: _ _ 6_"-~-~- --=---/1_li_'({2_9 --1-. --- I I ~ l THIS DOCUMENT HAS NOT RECEIVED PATENT CLEARANCE AND IS NOT TO BE TRANSMITTED TO THE PUBLIC DOMAIN I

I I I \\I II

• .'18 I

I ,te I I* I I

• I REQUIREMENTS FOR NEW POWER REACTOR CONCEPTS NEW TECHNOLOGY DEVELOPMENT PROJECTS February 1985 EG&G Idaho, Inc.

Idaho Falls, Idaho 83415

• Prepared for the U.S. Department of Energy Under DOE Contract No. DE-ACO7-76IDO157O I

ABSTRACT This report proposes a set of requirements and design goals for new power reactor concepts. Top-level requirements are competitive life-cycle costs, public acceptability, acceptable investment risk, and deployable before the year 2005. The requirements for public acceptability is interpreted in these requirements to mean proof of safety through a 11walk-away-safe 11 test. It is included in the event that proposed advanced light water reactors, despite their enviable safety record, prove unacceptable to the public, and this public attitude succeeds in thwarting nuclear industry revitalization with conventional light water reactors. In that event, reactors meeting this proposed set of criteria must become a backup to maintain the nuclear option. Based on these top-level requirements, other requirements and design goals are determined. It is expected that these requirements will be improved and expanded under review by DOE, the utilities, and the industry. ii I I I,, I.. 1 I I I I

I I

• I I

ii* ae I I I 1e I I I I I CONTENTS INTRODUCTION.......................................................... Background................................ *....................... Purpose of Report................................................. REQUIREMENTS AND DESIGN GOALS.........................................

1.

Competitive Life-Cycle Costs..................................... 1.1 Lower Capital Costs......................................... 1.2 Reduced Nuclear Plant Operating Costs....................... 1.3 Lower Nuclear Power Plant D&D Costs......................... 1.4 Extend Plant Life...........................................

2.

Public Acceptability............................................. 2.1 Demonstrated Inherently Safe Design.......................... 2.2 Environmental Impact Less Than Competitive Energy Sources.............................................. 2.3 Acceptable Public Perception of Operation and Maintenance............................................. 2.4 Sabotage Resistance......................................... 2.5 Diversion Resistance........................................ 2.6 Improved LWR Operation Perception...........................

3.

Acceptable Investment Risk....................................... 3.1 Readily Licensable Design................................... 3.2 Improved Accident Prevention and Management................. 3.3 Low Potential-Accident Recovery Costs....................... 3.4 Reduce Civil Liability Risk.................................. 3.5 Lower Capital Cost.......................................... 3.6 Reduce Utility Demand Projection Time and Demand Capacity Mismatch....................................................

4.

Deployable Before the Year 2005 4.1 Does Not Require Extensive and/or Long-Lead Time R&D........ 4.2. Shorten Construction Time................................... 4.3 Readily Licensable Design................................... 4.4 Utilize Proven Technologies................................. REFERENCES.......................................... *.................. ii i 1 1 4 6 7 8 11 16 17 19 20 22 25 29 26 25 28 29 30 31 33 33 33 34 34 35 35 35 36

1.

2.

3.

4.

5.

FIGURES Nuclear Power Plant Top-Level Requirements Requirements, Design Goals, and Possible Solutions for Competitive Life-Cycle Costs..................................... Requirements, Design Goals, and Possible Solutions for Pub 1 i c Acceptability............................................. Requirements, Design Goals, and Possible Solutions for Acceptable Investment Risk....................................... Requirements, Design Goals, and Possible Solutions for Deployment Before 2005........................................... iv 37 38 39 40 41 I I I I I.. 1 I I e1

1.

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I I I I I I 1e I I I I I REQUIREMENTS FOR NEW POWER REACTOR CONCEPTS INTRODUCTION

Background

Econom~c problems, slower than predicted growth rates, and public concern abo~t the safety of current generation nuclear power plants have I created a df facto moratorium on new orders of nuclear reactors in the United Stat~s. It is unlikely that there will be any new nuclear plant I orders withbut a significant change in electrical generating plant I economics, utility regulation, Nuclear Regulatory Commission regulation practices, public (and congressional) support, or electrical use growth rates. 1 Despite the current environment, it is in the national interest to preserve the nuclear option. 2 While alternative energy sources such as solar and geothermal have been successfully demonstrated on a limited scale, the economics and applicability of these technologies to large scale power produ~tion are highly uncertain. Given the current state of alternative 1 energy technologies, only the fossil-fuel and nuclear technologies are viable alternatives to meet ne~r-term central station electric power generation needs. Each of these energy sources has certain I inherent problems associated with its use. Although there is presently an abundance of oil and gas on the world markets, the price of these commodities remains relatively high compared with nuclear and coal prices, and the current glut will not continue indefinitely. Since a portion of the U.S. oil supplies are susceptible to international disruptions, it is necessary for the nation to develop energy alternatives to reduce our dependence on foreign supplies. The abundance of coal in the United States makes it an attractive energy source for production of electric power. However, concerns over acid rain and the accumulation of carbon dioxide in the environment raise 1

questions about the;advisability*of relying exclusively on coal-fired plants for the prediction of electric power in the United States. In addition, problems issociated with the mining and transportatiori of coal will continue to inbrease with increased use of coal for central station I power generation. Although there 1 are questions to be resolved relating to nuclear waste disposal and the environmental and public safety impact of postulated I severe accidents in nuclear power plants_, these questions may ultimat~ly prove easier to resolve than some of the current environmental concerns associated with the generation of electric power by fossil-fuel plants. The seleGtion of a specific energy source depends on many factors, including energy generation needs, energy source economics, fuel I availability, and national security. The ultimate direction taken by the i United State's utilities in the production of electric power, however, may I well depend on the Rublic perception of the environmental risks associated with the various enJrgy sources and the ability of the power industry to I adequately address these risks. In any event, until the environmental I concerns associatediwith the production of electric power by fossil-fuel I plants can be adequ~tely addressed, it is in the national interest to keep I the nuclear option open. I Many of the pr9blems facing the nuclear industry today are a result of the evolutionary process that led to the definition of curre~t generation l nuclear power plant~.* Current reactor designs were derived from technology I developed in the na~al reactors program. 3 The safety record of naval propulsion reactors !indicates that the original commercial reactors, based I on naval technology,i were most-certainly sufficiently safe as compared with other forms of energy generation. However, in an effort to reduce public '1 risk to an absolute :minimum, continual changes in. safety requirements were imposed on the designs. As it was a continually evolving process, vendors did not redesign th~ entire plant with each new requirement.

Instead, complex safety systems were developed and added to the existing reactor systems. Although this approach resulted in plant designs that are certainly adequately safe, the complexity 9f current designs has 2

I I I I I

I I I I I I I I I I I compromised plant operating characteristics and significantly increas~d plant construction costs. As a result, current generation nuclear power plants have generally not met utility expectation~ with respect to ease of operation, maintenance, availability, and overall plant economics. Several authoritative studiesl, 4,S,G have been undertaken to determine what is required to resolve current problems plaguing the nuclear industry. These studies indicate that while regulatory and other institutional problems must be resolved, a first step toward revitalization of the nuclear industry is the reassessment of current nuclear power plant designs and the development of improved designs or new concepts that better meet the needs of the utility companies. Many in the industry believe that the answer lies in redesigned light water reactors, 7 conforming to all current NRC requirements. They fear that the lead time to develop other concepts would be so long that the industry would not be ready to respond when new orders begin to be placed. They argue that redesigned water reactors, of relatively small size (400-600 MWe), could be built with short, predictable construction times; have little cost, schedule, or licensing risk; require sufficiently low investment so as to be attractive to a utility; and be simple to operate and maintain with good availability. These reactors would of course be adequately safe. Development of improved or advanced light water reactors is desirable because the technology is well established and is probably the most acceptable technology to a utility at the present. However, this approach alone may not be sufficient to recapture the eroded utilities' and public's confidence in the nuclear industry. In this case, it may be necessary to introduce a completely new reactor design that has been proven safe through a series of well publicized safety demonstration tests. 3

Purpo~e of Report This document is intended to define a set of requirements and goals for an advanced reactor system. The requirements and goals described in this document are predicated on the assumptions that: 1) nuclear power cannot become a viable option until the public is preponderately favorable to nuclear power and 2) the public will not become favorable to nuclear power with any less than a well publicized series of tests which

l.

demonstrate "walk-away-safe" characteristics in the proposed power plants. Although most of the requirements ~nd goals listed herein would be applicable to any reactor design, the additional requirement of public acceptability supported by a requirement of demonstrated ultimate safety are included in this proposed set. This set of requirements differs from those generally proposed for advanced reactors in one more significant respect--the time frame. The scenario visualized is not that of an advanced reactor replacing a viable light water reactor industry by evolution. Instead it is visualized as a coexisting supplement or as a backup in case the light water reactor industry revitalization is not successful. Thus, the time period for deployment approximately corresponds to the expected time period for the light water reactor revitalization program, i.e., new plants coming on line in about 2005. Light water reactor concepts may meet these requirements. In fact, some light water reactor concepts have been proposed to achieve public support through incorporation of walk-away-safe characteristics. Designers of other reactor concepts, such as gas-cooled reactors and liquid-metal-cooled reactors, believe that their,concepts can also be walk-away-safe. This set of requirements is not intended to replace or hinder the industry/utility initiatives to develop clean, small, readily-licensable light water reactors. Rather, the purpose of this document is to focus and provide direction to those nume.r:o~s other i.nitiatives that are ongoing and should continue. These other initiatives are necessary to assure the 4 ' I I..., --1 I I-

I t I.,,- 1 I I I

• 1 viability of an American nuclear option in the event that public opposition to light water reactors continues and succeeds in blocking the light water reactor industry revitalization.

In addition to the requirements which must be met to achieve public and utility acceptability, an attempt was made to define supporting design goals, which are desirable end points towards which efforts should be directed to achieve specific requirements. While all the goals defined in this document do not have to be met, accomplishment of these goals is believed to be the most expedient means of satisfying individual requirements. To aid in understanding the requirements and goals set forth, some possible design approaches or solutions to achieve the requirements and goals have been identified. Some of the solutions are concept specific, but they, of course, need not be met by any proposed design. It is expected that these requirements will be improved and expanded under review by DOE, the utilities, and the industry. The goal is to evolve the requirements until a national consensus is reached. In that away, new-initiative reactor development could proceed along a variety of technologies, but with common, understood requirements. Since the requirements and goals are still in the development stage, quantification of specific variables has been deliberately avoided. However, after the final requirements have been established, quantification of certain goals and requirements should be possible. With finalization of the requirements and goals, each new proposed concept can be judged on the basis of its ability to meet the established requirements. 5 . I

REQUIREMENTS AND DESIGN GOALS When public acceptability is included as a top-level requirement for any reactor to be acceptable to the electrical utilities, the list of top-level requirements becomes:

1.

Competitive life cycle costs

2.

Public acceptability

3.

Acceptable investment risk

4.

Deployable by the year 2005. These requirements are illustrated in Figure 1. Below these top-level requirements are progressively lower level requirements and design goals. Figures 2 through 5 identify the supporting requirements and design goals for each of the top-level requirements and illustrate the interrelationship between the various requirements and goals. Figures 2 through 5 also identify some of the possible design approaches or solutions. The following sections describe the requirements, design goals, and possible solutions in more detail than can be provided in the figures and justify the selection of the requirements and design goals. Generally, the text describes the figures from left-to-right and from top-to-bottom. Many of the requirements are interrelated as indicated by the transfer symbols on the figures. Close examination of the figures will reveal that some subheadings appear more than once under different headings of the figures. This occurs because several of the subtier requirements, goals, or possible solutions support more than one higher level requirement. Also, in some instances an item which may be designated as a requirement on one of the figures may appear as only a design goal on another figure. At first it may seem that an item designated as a supporting requirement on one figure should without further consideration be raised to the level of a requirement on the other figures. This was not done in order to maintain proper support relationships within each branch and to provide traceability to the true requirements. 6 ~ --1 I I I ~ e11 11 I I I I

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I -~ I I I ~ 1 I I I I

1.

Competitive Life Cycle Costs (Top Level Requirement) Designs for new nuclear power plant concepts must have projected life-cycle costs that are competitive with the electricity generation life-cycle costs of alternative electric energy generation sources. Regardless of other attributes of a new nuclear power plant concept, if the design is not capable of generating electricity at a cost that is competitive with other alternative generating sources, then the electric utilities and the public are unlikely to support plant construction and operation. Because of the capital intensive nature of nuclear power plants, competitive parity with competing energy sources with smaller capital costs will not be sufficient cause for utilities to order nuclear plants. A nuclear power plant must have a significant economic advantage over competitive energy sources to offset real and perceived financial risks and penalties associated with constructing and licensing nuclear power plants. Many people in the nuclear industry believe that nuclear power life-cycle costs must be 20% or more lower than those for coal fired plants for commercial attractiveness. The life-cycle cost of electricity is dependent on three primary cost categories. These are:

1.

The capital costs for plant construction, including the interest costs.

2.

Operating costs, including fuel cycle costs.

3.

The costs of decommissioning the plant at its end of life. Therefore, reduction in each of these cost categories are design goals for new nuclear power plants. Reduction of each alone is not a requirement, because any one could be profitably increased if it reduced the others significantly. 7

1.1 Lower Capital Cost (Design Goal) Soaring capital costs for nuclear power plants are a very important reason for the current dissatisfaction with new nuclear-electrical generation plants. Utilities have indicated that they cannot afford to tie up billions of dollars, often a substantial fraction of the total assets of the utility, in the construction of new generating plants. High interest rates or construction delays have caused significant cost escalations. Adding to the problem is the general practice of Public Utility Commissions to disallow inclusion of the capital costs in the utility rate base prior to full power operation of the plant. These financial problems have been a contributing factor for many cancelled plant orders. Therefore, in order that the life-cycle costs remain competitive with other power generation options, the high capital costs associated with the construction of new nuclear power plants must be significantly reduced. Supporting design goals for the reduction of nuclear power plant capital costs are: (1) shortening of plant construction time and (2) simplification of the nuclear plant design relative to current nuclear power plants. 1.1.1 Shorten Construction Time (Design Goal). A desirable construction goal is six years or less from start of construction to start of operation, as was achieved in the St. Lucie-2 plant construction. Shortening construction time will significa~tly decrease interest expense or loss of investment income. Shortened construction time will also decrease the investment risk exposure of the utility and will minimize the uncertainty in projecting utility generation requirements. Possible solutions or design approaches to shorten construction time are suggested below. 8 I I I I -I el el ~ I I I I ~ I I I I I

I I I,.,, lie . I -** I I I I I I I 1.1.1.1 Readily Licensable Design (Possible Solution)--Develop a design that is more readily licensable than current generation plants or a standardized design which can be readily pre-licensed. Licensing difficulties or regulatory problems and backfits often contribute to delays in plant construction and/or startup. Designing for ease of licensing will significantly reduce the current investment risk associated with possible delays in plant operation and significant cost overruns due to licensing problems. Possible design solutions or approaches for improving plant licensability are discussed in Section 3.1. 1.1.1.2 Capable of Improved Construction Management (Possible Solution)--Develop a design that is amenable to improved construction management (by selection of fabrication approaches, site layout, and design simplicity). 1.1.1.3 Standardize Design (Possible Solution)--Develop a standardized design that includes the balance of plant. Utilization of a standardized design will enable easier construction and licensing of subsequent plants, thus shortening construction time. 1.1.1.4 Serialized Factory Production (Possible Solution)-- Serialized factory production of certified and qualified components, systems and subsystems could significantly improve the ability to inspect and approve the plant systems. It should also reduce the potential for construction delays due to discovery of unacceptable components late in the construction cycle. 1.1.1.5 Optimize Shop Fabricated Systems (Possible Solution)-- Factory fabrication of systems, subsystems, and major components would minimize site field construction. This would ease construction management, improve quality control and inspection capabilities, and simplify Nuclear Regulatory Commission inspection and audit activities. 1.1.2 Simplified Design (Design Goal). A simplified plant design should reduce the number of needed support subsystems,* components, and controls. This will reduce the amount of materials, procurement 9

activities, construction time, manpower, and inspections. All contributions to a simplified design will lower capital costs. Possible solutions or design approaches to simplify plant design are suggested below. 1.1.2.1 Fewer Components and Systems (Possible Solution)--A new reactor design should minimize the number of systems and components in order to reduce the associated capital costs. Fewer components and systems will also improve plant availability, reduce maintenance expense, simplify plant operation and enable easier licensing. 1.1.2.2 Less Complex Systems (Possible Solution)--Less complex supporting systems and components should be included in the design. Many subsystems of current nuclear plants have complex controls and stringent operating requirements which add to the cost of components and construction. They also adversely affect maintenance, system reliability, and licensability. 1.1.2.3 Minimize Nuclear Grade Systems (Possible Solution)--A new nuclear plant design should minimize the number of nuclear (or safety) grade systems and components, especially for the balance of plant (BOP) and secondary cooling system. The capital cost of the total nuclear plant could be significantly reduced if the BOP and steam supply system could be designed to have no significant safety influence on the nuclear reactor. 1.1.2.4 Minimize Safety Systems (Possible Solution)--A new nuclear plant design should minimize the number and complexity of safety systems. Many safety systems have been quickly designed and added on to current nuclear power plants in response to regulatory requirements. These safety systems often have complex controls and instrumentation or redundant features in order to obtain the needed reliability. New nuclear power reactor designs should simplify the safety design philosophy and approach in order to help reduce capital costs and achieve higher*operational availability. 10 I I I I I el el ** I .. I I I I I I I

I I I,, I 1'- le I I II .*~ 1 I I I I 1.1.2.5 Minimize and Clearly Define BOP Interfaces (Possible Solution)--Nuclear island - BOP interfaces should be minimized and clearly defined. This possible solution, and the one which follows, are suggested to address a major factor in the high capital cost of nuclear power plants. That factor is the high cost of nuclear or safety grade piping and components as compared with those used in fossil-fired power plants. If the BOP systems, and even systems directly supporting nuclear reactor operation, can be clearly separated from the nuclear reactor and its primary cooling system and/or shown to not adversely affect plant safety by their failure or misoperation, then these systems could be constructed using lower cost materials and components with lower cost inspection and quality control requirements. This possible solution would also ease organizational interface problems between the reactor vendor, the different BOP designers, and constructors involved in the construction of a nuclear power plant. 1.1.2.6 Separate Safety - Non-Safet~ S~stems (Possible Solution)--This is not the same as the NRC separation requirement. The intent of this possible solution is to separate out all subsystems from a safety system that are not required to be part of the safety system. 1.2 Reduce Nuclear Plant Operating Cost (Design Goal) A second major cost contributor to the plant life-cycle generating costs is the operational expenses. These expenses include the cost of the fuel, operating manpower costs, repair and maintenance expenses, waste disposal, etc. Nuclear power plants will have higher non-fuel operating costs than most alternative electric generating sources because of the more stringent operating and safety criteria for nuclear plants. But the low costs associated with the nuclear fuel cycle when compared with fossil-fuels more than offset any disadvantage from high operating costs and permit nuclear plants to operate at relatively low net operating costs. However, there is considerable opportunity for further reduction in these costs through improved nuclear power plant design. Also, nuclear power plant operating costs have been steadily increasing (often in response to additional regulatory requirements). New nuclear power plant concepts need to attempt to reduce the potential for ratcheting operating expenses. 11

I. I Operating cost is directly affected by the electrical generating time and operating power level as measured by the operating capacity factor. Although the average capacity factor of nuclear power plants has been comparable to that for fossil-fueled plants, 1 nuclear power plants have generally not obtained the capacity factor expected of them. Only very well managed and operated plants have been able to achieve high capacity factors. The potential for obtaining a high capacity factor can be improved by better plant design. Supporting design goals for the reduction of nuclear power plant operating costs are: (1) simplify maintenance and reduce shutdowns, (2) improve fuel cycle economics, (3) reduce operational staff requirements, and (4) reduce active security requirements. Many of the following design goals and their associated suggestions for design solutions or approaches could involve capital cost increases which would need to be balanced against the potential operating cost savings. 1.2.1 Simplify Maintenance and Reduce Shutdowns (Design Goals). By simplifying and shortening needed maintenance activities, the time during which the reactor is shut down can be reduced. Reducing the number and duration of planned or forced outage times can significantly reduce operating costs per kWh produced. Possible solutions or design approaches to simplify maintenance and minimize shutdowns are suggested below. 1.2.1.1 Amenable To Inspection Ease (Possible Solution)-- Improve in-service inspection capabilities and develop a design that is amenable to inspection (provide for access to areas and components that will need inspection). 1.2.1.2 On-Line Refueling or Very Long Cycles (Possible Solution)--Develop on-line refueling capabilities or design a plant with a long operating cycle. A reduction in startup and shutdown cycles can also result in less system stress and the associated failures. 12 I I I I J ~ el I I I I I I

I I I I I,_ I I I 1 I I I I 1.2.1.3 Design for Maintenance Ease (Possible Solution)-- Design specifically for ease of maintenance and maintenance access. This includes provision for adequate shielding to limit worker radiation exposures. 1.2.1.4 High Reliability Components (Possible Solution)--High reliability components, as proven by testing or operational history, should be used to optimize plant reliability. 1.2.1.5 Readily Replaceable Components (Possible Solution)-- All components not designed to last the entire plant life should be readily replaceable. 1.2.1.6 Utilize On-Line Diagnostics (Possible Solution)-- Provide for on-line system and critical component diagnostics. State-of-the-art advances in such areas as signature analysis and artificial intelligence should be used to provide preventive maintenance prior to failure. 1.2.1.7 Design for Smaller Maintenance Staff (Possible Solution)--Develop a nuclear plant design capable of being serviced by smaller maintenance staffs including staff needed for shutdown operations. 1.2.2 Improve Fuel Cycle Economics (Design Goal). Although fuel costs for a nuclear power plant are relatively low, the fuel costs can be reduced or held at low values by good design. A total view of the plant economics and operation is required. Possible solutions or design approaches to improve fuel cycle. economics are suggested below. 1.2.2.1 Improve Fuel Utilization (Possible Solution)--Fuel utilization can be improved by designing to obtain high fuel burnup, using higher fuel enrichment, obtaining improved fissile conversion, higher thermal efficiency, etc. 13

1.2.2.2 Simplify Fuel Fabrication (Possible Solution)-- Simplify fuel fabrication requirements and/or lower fuel costs by avoiding. the use of exotic or hard to fabricate materials. 1.2.2.3 Optimize New and Spent Fuel Storage (Possible Solution)--The costs of on-site storage must be balanced with costs of shipping and storage elsewhere and with the potential for an extended shutdown should new fuel not be available or should on-site storage for used fuel be unavailable. 1.2.2.4 Minimize Waste Disposal and Transport Costs (Possible Solution)--Waste disposal and transport facilities and systems have been added as an afterthought to the design of many current nuclear power plants. Consideration of these facilities as part of the total integral design of a new plant should lower the operational costs associated with radioactive waste handling. 1.2.2.5 Integral Reprocessing Capability (Possible Solution)-- Fuel reprocessing and reassembly capability integral with the nuclear power reactor site could possibly result in improved fuel-cycle economics. This design option may also improve the diversion resistance of the fuel cycle and possibly improve public acceptability (see Section 2.5). 1.2.3 Reduce Operational Requirements (Design Goal). The size of nuclear power plant operational staffs has been steadily increasing in response to new emergency response requirements. New nuclear power plant designs must incorporate means to minimize staff requirements without affecting availability or other requirements and goals. Possible solutions or design approaches to reduce operational staff requirements are suggested below. 1.2.3.l Design for Smaller Staff (Possible Solution)--A smaller staff is required for a design having fewer and less complex systems. 14 I I I I I _, el I I I ea I I I I I

I I I I I le 1 I I 1 I I I I 1.2.3.2 Utilize Automation (Possible Solution)--Designs including automatic control and diagnostic systems can reduce operational errors and operator caused shutdowns as well as reduce staff requirements. 1.2.3.3 Minimize Required Operator Actions (Possible Solution)--Required operator actions during both normal and plant upset conditions can be reduced by utilizing inherently safe characteristics or by including automatic system controls and simplifying the design. 1.2.4 Reduce Active Security Requirements (Design Goal). Additional security requirements for nuclear power plants have led to significant increases in security personnel and their associated operational costs, even though this expense does not directly benefit plant operation. New reactor designs should attempt to minimize the security staff without compromising plant security. \\ ~ Possible solutions or design approaches to reduce active se~urity requirements are suggested below. 1.2.4.1 Layout Plant for Security (Possible Solution)--Design the plant layout for security: The site layout and placement of buildings and facilities can be such as to minimize the guard force size. 1.2.4.2 Use Low Enriched Fuel (Possible Solution)--The security requirements for a nuclear facility are significantly reduced when only low enriched (<20%) fuel is in use or stored. 1.2.4.3 Sabotage and Terrorism Resistant (Design Goal)--A nuclear power plant design that can be demonstrated to be sabotage resistant can be used to reduce the size of an active security force. This suggestion can, perhaps more importantly, also benefit public acceptability of nuclear power plants, as discussed in Section 2.4. 15

1.3 Lower Nuclear Power Plant Decontamination and Decommissioning (D&D) Costs (Design Goal) The third component of nuclear electric generation life-cycle costs is the costs chargeable to providing for eventual decommissioning and the associated decontamination of the plant and its site. However, the ability to easily and quickly decommission and decontaminate a nuclear power plant can be significantly affected by the plant design. Many of the design features which would improve the capability for D&D (and thus lower potential D&D costs) will also decrease maintenance costs. Possible solutions or design approaches to lower D&D costs are suggested below. 1.3.1 Simplify Cleanup Requirements (Possible Solution). Design for ease of decontamination (accessible, cleanable surfaces). This design suggestion could be important following an accident, and is thus possibly important for the reduction of investment risk. 1.3.1.1 Fewer Components and Supporting Systems (Possible Solution)--Fewer systems and components will make decontamination easier and quicker. This suggestion can also lower capital costs and maintenance costs. 1.3.1.2 Less Complex Systems (Possible Solution)--Simple designs should be easier to decontaminate and disassemble. 1.3.1.3 Readily Accessible, Cleanable Surfaces (Possible Solutior.)--The decontamination effort can be difficult and expensive if contaminated surfaces cannot be easily reached by decontamination personnel or robots. Design and development of special tools and equipment may be required if surfaces which must be decontaminated are inaccessible. 1.3.1.4 Removable Components and Systems (Possible Solution)--Site restoration is more easily accomplished with readily removable components and systems. 16 I I I I I ~. I I I I I I I I

"9" I I I I I le I I ,. I I I I I I 1.3.2 Decontamination Capabilities (Possible Solution). The ability to decontaminate and clean up the reactor system can be enhanced by design choices for materials and planning for D&D in the initial design. 1.3.2.1 Reduce Radioactivity Mobility (Possible Solution)--A design that has characteristically low mobility of fission products in the

• primary system is easier to decontaminate.

1.3.2.2 Minimize Long-Life Activation Products (Possible Solution)--A new nuclear plant design should minimize long-lived activation coolants and materials in the design. 1.3.2.3 Utilize Robotics for Cleanup (Possible Solution)-- Piping and components which may be highly radioactive can be placed in the plant design such that remotely operated tools or machines can be used for disassembly in order to reduce the manpower needed for such tasks or to reduce the time needed to wait for radioactive decay. 1.4 Extend Plant Life (Design Goal) The design of a new nuclear power plant can be such as to enable economic extension of the plant operating life beyond 30 to 40 years. Such a life extension will neither directly lower the capital cost of the new plant nor affect its operating costs during its design life. D&D costs would be decreased by the spread of such costs over a longer plant lifetime. The primary cost advantage is in the reduction in future utility capital expenditures for replacement electrical generating facilities. Two primary possible solutions or design approaches for enabling a future extension of the plant operating life are suggested below. 1.4.1 Reduce Radiation Damage in Long Life Components (Possible Solution). Radiation damage to key long life components, such as the pressure vessel and internals, is probably the most life-limiting characteristic of current nuclear power plants. Designing in radiation 17

protective barriers, such as neutron shields or water gaps, can significantly reduce the damage and extend the possible useful life of key components. 1.4.. 2 Design for Replaceable Components (Possible Solution). Modular plant design can provide for replaceability of key components at their end of life. This allows for possible economical plant operation until maintenance costs, new technology, or other factors make the plant obsolete and no longer competitive. 18 I I I I I el I I I I ~ I I I I I

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Public Acceptability (Top Level Requirement) Public acceptance of nuclear power as a viable energy source is the second top-level requirement. In the U.S., general passive acceptance by the public and some increased active public support appear to be the most viable mechanisms to reduce licensing delays, court interdictions, safety retrofitting in plants after construction, and financial,interest penalties relative to alternate energy sources. General public support for nuclear power is needed to provide the impetus for local Public Utility Commissions to allow cost recovery of work in progress on nuclear investments since the bulk of nuclear power life-cycle costs are incurred during construction. Much of the public resistance to the use of nuclear power for electric energy production results from: (1) the association with nuclear weapons, (2) a lack of technical understanding of complex physical phenomena, and (3) a distrust of large organizations. The TMI-2 accident demonstrated, to the public mind, that these concerns are valid. Many of the publ~c who had faith in the nuclear industry decided after TMI-2 that the intervenors were right and their trust in the industry and the NRC was misplaced. Public concerns are continually reinforced by media reports of problems associated with regulation and operation of nuclear plants and of operating incidents having consequences not immediately understood by the general public and, in some cases, incorrectly reported. General public acceptance and increased support will be regained only if the public can perceive clear, substantial cost advantages to the electricity consumer and readily understandable and inconsequential results of all credible operating events. Public conceins are principally associated with: o Accidents within the power plant caused by* design and manufacturing deficiencies, operational errors related to system comp'lexity or inattentiveness, or sabotage. 0 Fissile material diversion and public intimidation by terrorist groups or national entities. 19

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Environmental impact from radioactive wastes. The following design requirement and five design goals support the top-level requirement of public acceptability: (1) demonstrated, inherently safe design (requirement), (2) environmental impact less than competitive energy sources (design goal), (3) acceptable public perception of operations and maintenance (design goal), (4) sabotage resistance (design goal) and (5) diversion resistance (design goal). It is also important to the success of the next generation reactor . concepts that existing LWR plants continue to supply reliable, economical electrical power. However, improved public perception of the LWR industry is beyond the scope of this document. 2.1 Demonstrated Inherently Safe Design (Requirement) The lack of a universally accepted reactor design with unquestioned operating characteristics requires that nuclea*r power plant safety be demonstrated to the public. Plant safety features must be independent of the skill, a 1 ertness, and integrity of the pl ant operators and equipment manufacturers. Safety demonstration tests must include the full range of accidents and severe transients, including the consequences of credible sabotage. A prototype must be constructed, preferably full scale, and the appropriate safety tests must be conducted before a broad spectrum of public representatives having general public confidence. It is important that the general public, including knowledgeable nuclear critics, participate in the planning and conduct of the tests and that the plant response be readily interpretable and acceptable to the p~blic. Two supporting design requirements to provide a demonstrated, inherently safe design have been defined. 20 I., I I I el el* -, I I I

I I I I I le le I I I 1 I I I I 2.1.1 Design Amenable to Inherently Safe Operation and Control (Requirement). A design amenable to safe operation and control without reliance on operator actions should be a requirement of any new plant design. Possible design solutions supporting the requirement are passive fail-safe safety systems, slow plant transient response to initiating events, and low radioactivity mobility. 2.1.1.1 Self-Limiting Power (Reguirement)--The design must provide inherent power limitation to a level that can be accommodated by the dependable, long-term heat removal mechanism discussed below. The inherent power limit must consider all credible failures of active control devices. 2.1.1.2 Dependable Long-Term Heat Removal at Self-Limiting Power Level (Reguirement)--The design must assure long-term removal of the heat produced at the self-limiting power level. The long-term heat removal must consider all credible failures of active systems and passive coolant retention boundaries. 2.1.l.3 Passive and Fail-Safe Safety Systems (Possible Solution)--Fail-safe safety systems are acceptable from the public safety perspective, but may impact plant availability and thereby electrical generating cost by inadvertent initiation. Passive safety systems requiring neither automatic or human initiation nor active element function and relying only on natural physical phenomena are preferred. 2.1.1.4 Slow Transient Response (Possible Solution)--Slow plant response to initiating events is desirable since it would allow operators to easily identify transitions between plant operating states and to take corrective action if necessary. 2.1.1.5 Low Radioactivity Mobility (Possible Solution)-- Relative immobility of radioactive species is desirable under all credible plant conditions to limit transport mechanisms to public receptors. Relative mobility must be considered following an accident as well as during normal operations. 21

2.1.1.6 Simplified Advance Control Room Design (Possible Solution)-- Simplified control room design incorporating 11 state-of-the-art 11 control technology will allow better information display to the plant operating staff. This will permit operators to easily identify abnormal situations and take the appropriate corrective actions. 2.1.2 Demonstrable Inherent Safety to the Public by Test (Requirement). To allow public demonstration of safety by test, the design must facilitate the actual demonstration testing. This requires that the accident progression phenomena be repeatable, the final plant state be characterized, and the consequences be undeniably quantifiable and understood. 2.2 Environmental Impact Less Than Competitive Energy Sources (Design Goal) Environmental impacts from energy conversion processes are, in most cases, not obvious to the public nor are the biological effects readily quantifiable. Sulfur dioxide, carbon dioxide, radioactive gases, and other effluents are invisible and, in some cases, odorless, and the biological effects are complex and not universally accepted. The envi~onmental impact concerns of the public are radiation releases, waste heat rejection, and, to a lesser extent, physical plant land commitment and visual impact. Minimization of the potential for radiation release, waste heat rejection, and physical plant environmental impact offers a possible solution to these concerns. 2.2.1 Minimize Potential for Radiation Release (Design Goal). The public has been repeatedly told that normal operational radioactive releases cause no significant health effects and that significant, unplanned releases are so improbable that they cause no health concern. However, disclosures of inadvertent radioactive releases and the NRC required emergency action plans, including bi-monthly exercises involving publicly audible alarms, have raised concerns in the public mind. The public cannot be expected to interpret the health aspects of radioactive 22 I I I I I el el -, I I I I I I I I

I I I I I le le I I I ~ ' I I I I I releases. They do not accept the interpretation of the operating utility, and their concerns are regularly reinforced by emergency action exercises. Minimizing the potential for radiation releases is supported by a design goal to eliminate the potential for unplanned releases. Desirable design solutions also reduce the radiation source term, provide for negligible normal release, minimize spent fuel handling and on-site storage, minimize waste disposal and transport, and produce low mobility radioactivity. 2.2.1.1 Eliminate Potential for Unplanned Release (Design Goal)--An obvious design goal that would reduce public apprehension is to eliminate, or reduce the risk from, credible unplanned releases to the extent that off-site evacuation plans and the attendant exercises are not required. 2.2.1.2 Reduce Radiation Source Term (Possible Solution)--To a first approximation, all nuclear power plants will generate the same fission product inventory per unit of power production. However, the quantity of induced radioactivity and the physical mobility of both the fission products and the induced radioactivity can be altered by design processes. 2.2.1.3 Design for Negligible Normal Release (Possible Solution)--The release of gaseous or liquid radioactive effluents will always appear to the public to be detrimental. Designs should include on-line coolant cleanup systems (filters, traps, etc.) to minimize release quantities, and unfiltered pathways should be eliminated. 2.2.1.4 Minimize Spent Fuel Handling and On-Site Storage (Possible Solution)--Spent fuel handling and on-site storage pose radioactive release potentials subject to human error or severe natural phenomena. The relative risk of on-site storage must be weighed against risk of transport. 23

2.2.1.5 Minimize Waste Disposal and Transport (Possible Solution)--The source strength and volumetric quantity _of radioactive waste that requires off-site transport, and thus poses a radioactive release potential, should be minimized. For example, Reference 5 recommends on-site storage for 50-100 years to reduce transport risks. However, the risk of on-site storage must be weighed against the risk of transport (see Section 2.2.1.4). 2.2.1.6 Low Radioactivity Mobility (Possible Solution)--The relative mobility of radionuclides within the nuclear power plant affects the assessment of potential environmental consequence. Design objectives are enhanced by relative immobility under all credible plant conditions. Relative mobility is strongly affected by selection of fuel form and coolant. 2.2.2 Minimize Waste Heat Rejection Environmental Impact (Possible Solution). Waste heat is generally rejected either in the form of water vapor (cooling towers or evaporative ponds) or as an elevated temperature liquid stream entering natural water bodies. Cooling tower effluents carry objectionable salts used for water chemistry control. Vapor release has the potential for objectionable visual effects and downwind icing. Elevated temperature liquid effluents entering natural water bodies may be detrimental to existing aquatic ecosystems. It is publicly advantageous to minimize objectionable or indeterminate environmental effects associated with waste heat rejection by reducing the amount of effluent or discernable differences between the effluent and the receptor media. To this end higher efficiency systems have a distinct advantage. 2.2.3 Minimize Physical Plant Environmental Impact (Possible Solution). It is desirable to minimize the required land allocation, the operating visual effects, and land use restrictions subsequent to decommissioning and to incorporate physical appearances compatible with the environment (underground plants, transformer guards, and distribution systems). 24 I I I I I el I I I I I I I I

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1 I I I I 2.3 Acceptable Public Perception of Operations and Maintenance (Design Goal) Public disclosures of poor operation and maintenance practices by some operating utilities supports the general public distrust of large, impersonal organizations. NRC imposed fines and the occasional appeals of the fines further cloud the real issues and heighten public apprehension. Public perception of operations and maintenance is enhanced by designs that simplify operations and maintenance and reduce forced shutdowns. This design goal is supported by design solutions that reduce operational radiation exposure, minimize required operator actions, and minimize waste disposal and transport. 2.3.1 Simplify Operations and Maintenance and Reduce Forced Outages (Design Goal). Plant design can improve public acceptance as well as reduce operating costs (Section 1.2.1) by reducing the frequency of operating or operations. presented in maintenance actions and by simplifying the involved Potential design solutions supporting this design goal Sections 1.2.1.1 through 1.2.1.6. are 2.3.2 Reduce Operational Radiation Exposure (Possible Solution). Disclosures of operational exposures are often interpreted by the public to indicate defective design or poor operational and maintenance practices. Reducing operational exposures will enhance public acceptance. 2.3.3 Minimize Required Operator Actions (Possible Solution). Operator action always carries an associated risk. A reduction in required actions by design will contribute to reduced operating cost (see Section 1.2.3.3) and will be reflected by enhanced public acceptance. 2.3.4 Minimize Waste Disposal and Transport (Possible Solution). Nuclear waste hazards are not well understood by the public and have therefore been successfully sensationalized by anti-nuclear and environmental activists through the public information media. Transportation subjects waste to additional sources of possible accident 25

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initiators. Reducing waste disposal and tran~port allows additional decay time, reduces the number of accident initiators, and reduces potential environmental impacts (Section 2.2.1.5). It also reduces the negative aspect of the public perception of nuclear plant operations and maintenance. 2.4 Sabotage and Terrorism Resistance (Design Goal) The public views nuclear power plants as complex, high technology devices that are difficult to control under the best of conditions and therefore a target for sabotage or terrorism that could result in serious consequences to both the operating staff and the public. Plant sabotage resistance can be increased by possible design solutions that provide inherent safe operation and control, provide inherent security features, and minimize required operator action. Public acceptance can be significantly improved by incorporating sabotage considerations into the demonstration of inherent safety. 2.4.1 Amenable to Inherent Safe Operation and Control (Possible Solution). A plant that is amenable to inherently safe operation and control supports the requirement of demonstrated, inherently safe design (Section 2.1.1) and the goal of sabotage resistance. Supporting design requirements and possible design solutions are discussed in Sections 2.1.1.1 through 2.1.1.5. 2.4.2 Design in Security Features (Possible Solution). Sabotage that can have public consequences can be made more difficult by reducing the number of vulnerable systems and by isolating and imposing access restrictions to the vulnerable systems. 2.4.3 Minimize Required Operator Actions (Possible Solution). This is a possible solution that provides additional sabotage resistance by reducing human intervention requirements. It also improves public perception (Section 2.3.3) and reduces operating costs (Section 1.2.3.3). 26 I I I I I _, I I I I I I I I

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1 I I I I 2.5 Diversion Resistance (Design Goal) Diversion of weapon grade material in a form that can avoid detection and that can readily be assembled i~to a bomb for public intimidation is both a governmental and public concern. Diversion resistance can be enhanced by design solutions that reduce external flow of plutonium and highly enriched uranium, utilize high activity reprocessing, provide integral reprocessing, contain inherent security features, and/or use low enriched fuel. 2.5.1 Reduce External Flow of Plutonium (Possible Solution). Plutonium is erroneously perceived by the public as the easiest material to process into a weapon. It is most vulnerable to theft when outside the security perimeter of the power plant. Reactor designs which utilize longer fuel cycles or provide for on-site reprocessing (discussed in Section 2.5.3) can reduce the required external flow of plutonium. 2.5.2 Utilize High Activity Reprocessing (Possible Solution). Retention of radioactive contaminants facilitates detection and requires* more sophisticated techniques for stealing and,ubseqent ~rocessing to obtain weapon grade material. However, this must be balanced against the potential for increased operational exposure (Section 2.3.2) and increased fuel fabrication costs associated with additional remote fabrication needs (Section 1.2.2). 2.5.3 Integral Reprocessing Capability (Possible Solution). Integral reprocessing, as proposed for the Integrated Fast Reactor (IFR), reprocesses the fuel within the security perimeter of the power plant. It also retains sufficient radioactive contaminants to ease detection and to require sophisticated reprocessing in order to obtain weapon grade material. 2~5.4 Design in Security Features (Possible Solution). Diversion can be inhibited by isolation of the plutonium to restricted access areas and increasing surveillance and detection procedures at the security perimeter. 27

2.5.5 Use Low Enriched Fuel (Possible Solution). Unirradiated low-enriched fuel (<20% u235 ) requires further enrichment to make weapons grade material. Irradiated low-enriched fuel is highly radioactive and req.Liires reprocessing to obtain weapons grade material. Both of those factors enhanc~ th~ diversion resistance of low-enriched fuel over htghlY enriched fuel. 2.6 Improve LWR Operation Perception Successful operation and improved public perception of both the cost and risk associated with current light water reactor electrical power production are of extreme importance to the future acceptability of nuclear power. Light water reactor operations, however, are beyond the scope and purpose of thi~ doc~ment.

3.

Acceptable Investment Risk (Top-Level Requirement) The third top-level requirement for a new nuclear power plant is an acceptable investment risk. Utilities considering investing in new generating capacity must have assurance that the selection of the nuclear option will provide acceptably low cost risk associated with plant construction and ~peration in comparison with other methods of po~er generation. Construction of any major p6w~r plant has some degree of risk. However, at the present time, construction of nuclear power plants is a high risk undertaking. This is caused primarily by the long construction time, which increase~ uncertainties in power demand forecasting, constr~ction cost esc~lation, construction financing (interest rates), and

• licensing changes.

Nuclear plant operation also has risks associated with plant* availability, accidents, and plant recovery that can be far more financially damaging to utilities than similar events for other energy sources. The TMI acc~dent and recent plant cancellations have demonstrated to the utility industry the investment risks associated with nuclear power* plant constru~iidn a~d ownership: Clearly, utilities will not invest in a 28 I I I I I el el I I I a: -, I I I I

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I I I I I new concept nuclear power plant unless they have some assurance that the plant can be constructed and licensed in a reasonable timeframe and can be easily operated with little risk to their capital investment. The requirement to achieve an investment risk comparable with other forms of energy generation lead to four supporting requirements and two design goals, namely: (1) a readily licensable design (requirement), (2) improved accident prevention and management (requirement), (3) low potential accident recovery cost (requirement), (4) low risk of civil liabilities (requirement), (5) low capital costs (design goal), and (6) reduction of the need for long-time forecasts of electrical demand (design goal). 3.1 Readily Licensable Design (Requirement) Uncertainty in licensing due to changing requirements, licensing delays, litigation, etc., leads to investment risks that are unacceptably higher for nuclear power plants compared with other power generation methods. Therefore, new concepts for nuclear power plants must be based on a design that is easily licensed. The currently proposed licensing.reform may stabilize the licensing process for LWR's, but the introduction of new reactor concepts and/or technology may result in~ return to licensing uncertainty. 3.1.1 Demonstrated Inherently Safe Design (Design Goal). A design goal supporting this requirement is to produce an inherently safe reactor in which safety can be demonstrated by testing. (See Section 2.1.1 for the requirement of demonstrable inherently safe deiign). A reactor ~esign that has been shown by demonstration tests to be safe during accident situations should minimize the investment risk associated with licensing. 3.1.2 Design and Technology Amenable to Licensing Ease (Possible Solution). By using a design and technology base that have been shown by experience to be licensable, the impact of the licensing process on construction time and cost can be minimized. 29

3.1.2.1 Amenable to Inspection (Possible Solution)--The design should consider the verification inspections required to assure that components meet the appropriate design standards. Inservice inspection during the operating life of the plant should be emphasized from the onset of the design. 3.1.2.2 Standardized Design (Possible Solution)--The attributes of standardized design have long been recognized as a mechanism for reducing licensing delays. Because of ratcheting of licensing requirements, diverse design requirements imposed by the large number of U.S. nuclear utilities, regional requirement variations (such as seismic, water supply, etc'.), and the involvement of several vend6rs and architect/engineer organizations, the U.S. has not benefited from siandardization to the extent experienced in scime other countries. 3.1.2.3 Certified Qualified Components (Possible Solution)--The use of components whose designs have been qualified by test and are certified to me~t the design requirements will redu~e the risk associated with licensing. 3.1.2.4 Simplified Design (Possible Solution)--Simplified design is discussed in Section 1.1.2. 3.1.2.5 Utilize Proven Technologies (Possible Solution)-- Designs utilizing proven technology will generally have a cost and schedule advantage over ihose based on unprove~ and untested technology. 3.2 I~proved Accident Prevention and Management (Requirement) Ari' imp6rtant requirement for new plant designs is the inclusion of design features that facilitate the prevention and management of acc~dents which pose a significant financial risk to utilities. Accident prevention. and management for current plants is predicated on the need to ensure public safety following a severe accident. With this approach, the financial risk to utilities fr6m le~s severe accidents is not addressed. Designing for accident prevention and manag~ment with the intention of 30 I I I I I.. I I I ( _, I I I I I

I I I I I ~ le I I I 1 I I I I protecting utility investment in new plants is a more demanding requirement because it necessitates the consideration of both the low probability high consequence accidents affecting public safety and the more probable accidents that can be costly to utilities but have little impact on public safety. 3.2.1 Amenable to Inherent-Safe Operation and Control (Design Goal). A design goal supporting this requirement is to design a plant amenable to inherent safe operation and control (see Section 2.1.1 for a discussion of this goal and possible solutions). 3.2.2 Utilize Accident-Diagnostics and Control (Possible Solution). A possible design approach for accident prevention and management to minimize utility investment risk is to utilize advanced accident diagnostic and control systems. Even plants with demonstrated inherent safety characteristics can benefit from the use of artificial intelligence and computer control systems. The financial impact of plant downtimes associated with regulatory reviews, plant cleanup, and restart can be minimized by minimizing the extent and severity of even the mildest plant accident or transients. 3.3 Low Potential-Accident Recovery Costs (Requirement) This requirement will force the nuclear plant design to incorporate features such that recovery costs from all potential accidents will be low. Consideration should be given to both the length of time and magnitude of effort required for cleanup and component replacement. 3.3.l Design for Ease of Cleanup and Replacement (Design Goa1). By considering plant cleanup and component replacement and repair as an integral part of the design requirements, designs that reduce the recovery costs of both plant and components can be achieved. Any added capital cost of these design features will have to be balanced against the anticipated cost savings during recovery and the cost savings resulting from a rapid recovery. 31

3.3.1.1 Low Radioactivity Mobility (Possible Solution)--Designs that inherently maintain radioactive materials in solid forms and in an immobile state will reduce cleanup costs since the radioactivity will remain localized. 3.3.1.2 Utilize Robotics for Cleanup (Possible Solution)--Plant designs incorporating remotely operated robotic machines for cleanup and component replacement and/or repair can reduce potential post-accident costs. 3.3.l.3 Readily Accessible Cleanable Surfaces (Possible Solution)-- All surfaces in a nuclear plant should be easily cleanable, as it is impossible to predict with certainty which surfaces may become contaminated. 3.3.1.4 Readily Replaceable Components (Possible Solution)-- Components that can become damaged and/or contaminated and that cannot be readily repaired or cleaned should be easily replaced, possibly remotely. Modularization of entire systems is one possible solution. 3.3.1.5 Fewer Components and Systems (Possible Solution)--Plant designs should minimize the number of systems and components that are located in areas that have the highest potential for becoming contaminated during an accident. 3.3.1.6 Less Complex Systems (Possible Solution)--Systems having few components are usually easier to clean than more complex systems. 3.3.1.7 Minimize Long-Life Activation Products (Possible Solution)--Whenever possible, materials that are expected to become activated during normal operation or in an accident should be selected such that the specific.activity of the activation products are low. 3.3.1.8 Minimize Nuclear - BOP Interfaces (Possible Solution)--By minimizing the physical interface between the NSSS and the BOP, the spread of radioactive contamination can be limited.

i 32 I

I I I I el el I I I I I I I I

I I I I I 1le..,e 1* I I I I I I 3.4 Reduce Civil Liability Risk (Requirement) This requirement is to minimize the risk of any civil liabilities resulting from operation of the plant and applies to both normal operation as well as any accident situation. By reducing the potential for radiation exposure to plant personnel and the general public, the risk of civil liability should be minimized. 3.4.1 Amenable To Safe Operation and Control. (Design Goal). This design* goal is discussed in Section 2.1.1. Achievement of safe operation and control

• will result in a corresponding decrease in liability risk associated with operation.

3.4.2 Minimize Potential for Radiation Release (Design Goal). This design goal is discussed in Section 2.2.1.. By minimizing any radiation r.elease, the risk of civil liability will be reduced. 3.4.3 Reduce Operational Radiation Exposure (Possible Solution). Civil liability risk can be reduced by designs that reduce operational radiation exposures. 3.5 Lower Capital Costs (Design Goal) A higher risk is acceptable for a low investment than for a high investment. (See Section 1.1 for a discussion on the design goal of lower capital costs and possible desi~n solutions.) 3.6 Reduce Ut.ility Demand Projection Time and Demand Capacity Mismatch (Design Goal) The further into the future that demand projections must be forecasted. the larger are the uncertainties in the projected load values. Long lead times for current LWR plant construction have resulted in plant cancellation when load demand forecasts change and new forecasts indicate lower demand. The investment risk associated with uncertainties in forecasts of future load demands should be independent of the method of power generation. 33

3.6.1 Shorten Construction Time (Design Goal).* A method of decreasing the uncertainty i_n forecasting is to shorten construction time. (See Section 1.1.1 for possible methods to shorten construction time:) 3.6.2 Size Reactor To 100-600 MWe (Possible Solution). Another design solution to attain the goal of reducing the mismatch between forecast demand and actual capacity would be to size a reactor in the 100-600 MWe range so that capacity could be added to the grid in smaller increments.

4.

Deployable Bef~re the Year 2005 The fourth top~level requirement for a new nuclear plant is that the plant must be deployable by the year 2005. The basis for this requirement stems from two considerations. First, the projected U.S. demand for electricity is such that current fossil fuel extraction, transportation, and combustion techniques may impose an unacceptable social and environmental burden'. Socially acceptable, alternate energy sources will be minor unless there are scientific breakthroughs that.are neither identifiable nor schedulable at the present time: Second, since conitruction of currently ordered nuclear reactors will be completed in the early 1990 1s, the construction talent will begin to disperse at that time. The design and nuclear component fabrication infrastructure will begin to erode even earli~r unlEss there are new orders or other financial inducement to maintain the i~frastructure. Since the current infrastructure will. s_oon begin to erode I a major technology development and deployment effort must start now--both to maintain the current infrastructure and to meet the anticipated electrical energy demand projected for the next century. 4.1 Does N~t Regui~e Ex~~nsive and/6r Long-Lead Time R&D (Requirement) A cons~q~ence,of the top-level requirement is the requirement that the plant design m~st not require the _support of extensive long-lead time research and developmen~ astivities. If the technology to support a new reactor concept requires Jpng~lead time research, it will not be possible to deploy a new plant by 2005. 34 I I I I I.... -, I I I I I I I

I I I I I....,e I I I I I I-I I 4.2 Shorten Construction Time (Design Goal) Shortening construction time will allow greater time for completion of engin~ering design work before start of construction. Th~ other desirable effects of shortened construction are discussed in Section 1.1.1. 4.3 Readily Licensable Design (Design Goal) A readily licensable design will reduce the likelihood of delays during the construction phase. Other aspects of readily licensable design are discussed in Section 3.1. 4.4 Utilize Proven Technologies (Possible Solution) The impact on plant deployment will be minimized by utilizing proven technology-to--the maximum extent possible in the design of new nuclear plants. 35

REFERENCES

1.

Nuclear Power in an Age of Uncertainty, OTA-E-216, February 1984.

2.

The National Energy Policy Plan, DOE/S-0014/1, October 1983.

3.

Golay, M.E., 11An Agenda for Improving Present-Day Reactors, 11 Technology Review.

4.

Lester, R.K., et al., Nuclear Power Plant Innovation for the 1990s: A Preliminary Assessment, MIT-NE-258; September 1983.

5.

Weinberg, A.M., et al., The Second Nuclear Era, ORAU/I.EA-84-6(M), March 1984. 6, Trauger, D.B., 11Nl:Jclear Power Options Viability Study, 11 Sixth Annual International Conference on the HTGR, San Diego, California, August 13-14, 1984.

7.

Stahlkopf, K.E., 11The Next' Generation Light Water Reactor, 11 19th Intersociety Energy Conversion Engineering Conference ProceecITi;gs, August 1984, Paper 84 9.539, pp 1570. 36 I I I I I.. ,} -, I I I I I I I I

w "-J COMPETITIVE LIFE CYCLE COSTS REOU IREM ENTS FOR THE NEXT GENERATION OF NUCLEAR . POWER PLANTS PUBLIC ACCEPTABILITY I I ACCEPTABLE INVESTMENT RISK I DEPLOYABLE BEFORE YEAR 2005 INEL 4 0675 FIGURE 1. N~CLEAR POWER PLANT TOP-LEVEL REQUIREMENTS

I I I I I I I I I I I I Fewer Less systems Amenable to inspection ease n-line g or ver cycle ease Design for smaller Top level Requirement Competitive Life Cycle Costs Improve fuel Integral Deslgn for* smaller staff Utilize Minimize required operator actions Layout plant for security Requirement FIGURE 2. L.ess A. Transfer Ll1a: INEL 4 0629 REQUIREMEfJTS, DESIGIJ GOALS, Ar!D POSSIBLE SOLUTIONS: FOR C011PETITIVE LIFE-CYCLE COSTS 38

I I I I I I I .1 I I I I I Amenable to inherent safe operation & control Demonstrated inherently safe design Self-limiting power Dependable long-term heat removal at self-limiting power level Passive and fail-safe safety systems Slow transient response Demonstrable inherent safety . to the public by test Reduce radiation source term Design for negligible normal release Minimize spent fuel handling & on-site* storage Minimize waste disposal & transport Low radioactivity mobility Minimize e heat reje nvironment impact Minimize hysical pl nvironmen impact Top Level Requirement Public Acceptability Minimize required operator actions Minimize waste disposal & transport Requirement Design in security features ~----------------, I I l Improve I I LWR operation I perception l I I I I I I __________________ J Use low enriched fuel Possible solution A Transfer Uta: INEL 4 0631 FIGURE 3. RE 1QUIREMEfHS, DESIGrJ GO/\\LS, AND POSSIBLE SOLUTIONS FOR PUBLIC ACCEPTABILITY 39

I I I I I I I I I I I I Readily licensable design Design & technology amenable to licensing ease to inspection design Certified qualified components Simplified design Utilize Improve accident prevention & management Top Level Requirement Acceptable Investment Risk Low potential accident recovery costs Low radioactivity mobility Utilize robotics for cleanup Readily accessible cleanable surfaces Readily replaceable components Fewer Less complex systems Minimize long-life activation products Reduce civil liability risks Size reactor to 100 to 600 MWe l Requirement Transfer to: INEL 4 0630 FIGURE 4. REQUIREMENTS, DESIGN GOALS, AND POSSIBLE SOLUTIOfJS FOR ACCEPTABLE IIJVESTt1ENT RISK 40

I I I I I I I I I *' 1e I I I I I Top Level Requirement Deployable By Year 2005 Does not require extensive and/or long-lead lime R&D Utilize proven technologies Requirement A Transfer LJto: INEL 4 0632 FIGURE 5. REQUIREME[ffS, DESIGN GOALS, Arm POSSIBLE SOLUTIONS FOR DEPLOW1ENT BEFORE 2005 41

/ April 15, 1985 Secretary oora1 IIUllll1I PR ~ IUU! ~--.Q(}, C./SCJ r-R. II ~ PROFESSIONAL ANALYSIS,.INC. P. 0. Box 1135;._ Oak Ridge, Tennessee:37830 \\ USNl~C _, (615) 483-5679 15 APR 18 AU :20 U.S. Nuclear Regulatory Ccmnission Washington, D.C. 20555 Re: Gentlenen: Proposed Policy for Regulation of Advanced Nuclear Power Plants I have read the above referenced proposed policy and offer the following thoughts. Concerning the NRC's charter of protecting public health and safety and the environment, the Commission has done exceptionally well. I know of no other federal agency with responsibility for an industry of several hundred thousand workers generating an annual gross product worth twenty billion dollars, that can claim almost no fatality or heavy losses to the public. The fundamental problem that the NBC was forced into by regulatory evolution is that it tries to design nuclear plants by regulation, hence it robs industry of incentive for effectiveness and responsibility. With the above thoughts, the following comments correspond to the specific questions raised in the proposed policy.

1. Less prescriptive design objectives such as performance standards should be the NRC's regulatory approach. The most encompassing standard should be the safety goal that a nuclear power plant should not add significantly (say 0.1%) the risk already faced by any member of the public. It must also add insignificantly to the environmental burdens.

Reactor core power density, reactor core heat removal, containment, and siting are all components of the above standard. A LMFBR may have a higher core power density than a LWR but can still meet the standard. A small HIGl may not require a containment. A small PIUS may be located in the center of a city.

2.

Performance standards should be required of reactors (advanced or current) in connection with a) safety margin, and b) time margin. Whether the safety features are "inherent," "passive," or "active" should be up to the designer to design and defend. AclaiOwfedatd by ctfd.*

r I ~. ~

=

)> --~ ~ -I ~ t~ .,_ ~~ 0 :c..,. vi en ~ I I ~

t Conditions that exceed the design basis" must be limited to "acts of God." They must be rational after the "act of God."

3.

Simplicity of design and operation must be a design criterion. Emergency actions should be limited to seven acts or less and should not require the operator to look up procedures within the first half hour of an incident.

4.

An unified set of general design criteria must be established that is applicable to all reactor designs. This set must by necessity be very general and simple. Specific interpretation of the criteria for each reactor design can be made but should be considered details that can be implemented in a non prescfiptive fashion.

5.

This question is full of subjective and prescriptive content. The NBC should stay away from the word "favor" or "cost-benefit balancing." Modern technologies are by definition very complex. It will be up to the designers to explain how their "complex" designs satisfy the NRC simple requirements.

6.

Proof of safety is all NRC should be concerned with. As problems with safety of concern to the NRC have very low probabilities of occurrence, a prototypical plant demonstration will not be sufficient to provide proof of safety. Therefore, only component proof of safety need be demonstrated. Commercial licensing can be carried out by the NRC when it is satisfied that component proofs of safety coupled with a simple risk combination analysis satisfy the overall safety goals. The economic risk should be up to the vender and the applicants to assume. I will be happy to clarify the above comments if you are so interested. In any event, I hope to have the opportunity to further interact with the NRC in this very important development of advanceq power reactors. DLP:td 2 Sincerely yours, an L. Phung, Ph.D., President

Federal Register / * '(ol. 50, No *. *_:59 *-/. Tn~day, *-Mar.ch 26,.198'5../ :Proposed:*Rtile*s

• di~trict in which the subpoena was.

issued to take the action referred to in the preyious sentence in the event the- .witness neglects ou.efuses.to appear and testify as directed by the subpoena

• serv&l upon him.

(Secs. 103 and 287 of the Immigration and Nationality Act, as amended'(8 U.S.C.1103, 1357))

• Dated: March 8, 4.985.

Alan C. Nel5on, Commissioner, Immigration and Naturalization Service. [FR Doc. 85-7056 Filed 3-25-85; 8:45 am] BILLING CODE 4410-10-M -4111iEPARTMENT OF AGRICULTURE .ood -~fety and Inspection Service 9 CFR Part 352 .cket No. 83-038Pl Munta::-lnspection of Buffalo Wrrection . In FR Doc. 85-'6178, beginning on page 10776, in the issue of Monday, March 18, 1985, make the fqllowing corrections: 1 *.On page 1077a, first column. in the

• second par~aph of the "Summary", the second line should read:

"alternative locations for inspection personnel to perform ante-mortem inspection of buffalo: (lf In the field in a".

2.

• On the same page, in the second column. third line, the first.word should read *~products".

a.. In the.same column, under "SUPPLEMENTARY INFORMATION, in.the first paragraph, fourth.line from the l orn of.that paragraph "State" should d "SJates". On page 10779, column one, first full ~ * ,~graph, fifth line, the second lime "consumer"., appears, it should read "consumers".

5. In the same column, last paragraph, A'erith line from the bottom, "areas" wr,uid read "area".

6. In column two, in the third full paragraph, third line, the first two words should read:.. must 1insure", and a period should be placed at the end of the last word in that paragraph.

7. ln*column three, second full paragraph, line three, "and" should read "are".

8. In the same column, last paragraph, fifth line, "it" should read "It.

PART352-{C0RRECTEDJ

9. On page 10780, in the table of contents for Part 352, in Ute entry fW' "352.12'.' the first time "or" appears it should i:ead "of'.

§ 352.1 i~rrectedL,

10. On the same page, column two, in

§ 352.1, first paragraph, Jifsf Jine/th~. second word should read."defmitions". § 352.4 CCorrectedJ

11. On page 10781, column one, in

§ 352.4, paragraph {cl/in the fmirth line, "peform" should read "perform". § 352.7 (Corrected] *

12. On page:101a2::ee1/2ndpolµm~,;i11 *-

§ 352.7, paragpaph-{a}, line two,- "inspection" should read inspected". § 352.10 [Corrected]

13. On page 107-83_,.in column three,. in

§ 352.10, paragraph {b)U) the last word should read .in~pectiori". BILLING CODE 1505,01-M NUCLEAR REGULATORY COMMISSION 10 CFR Part 50 Proposed Polley for RegulaUon of Advance Nuclear Power Plants AGENCY: Nuclear Regufatory Commission: ACTION: Propmred roncy statement.

SUMMARY

The-Commission intends to improve the licensing'envirorunent for advance nuclear power-i-eactors to minimize complexity,and uncertainty in the regulatory process. Advance reactors are defined as reactor designs

. which are *significantly different 'from . the present generation fight water

• reactors. It is anticipaterlihat these designs-will reflect the benefrts of -

significant research: and tlevelopment work,* and include *the experience -g¢ned in'9perating the.many*power and deyelopmental:reactors both in the United States and throughout the world. Since the wealth.of analyses, research, development and operating experience provide useful insight to designers, it is also expected these-reactor plants will have an enhanced margin,of.-safety *. To provide regulatory guidance during the development of advance reactor design. the Commission wishes to encourage *the earliest possible inter.action between

• other government -agencies, designers,.

potential licensees and the NRC. The proposed policy statement sets forth the general cllaracteristics of advanced reactor design whk:h the Commission believes will contribute to increased assurance-0fsafety, to better public , understanding, and to more effective regulation. As.the.agency responsible for protecting.the public from the potential hazar.ds of nuclear-power* plants, the Commission will keep the public infonned ofits,judgmenton ~e known aruhmknownsafety aspects of _ adv.anced -reactor-designs as *they come

• before the'.Conmiission.
• DATES: The *commentperiochxpires '.

April 25, 1985. -* ;.

• ADDRESSES: Seni written comments:or-.

suggestions 'to the Secre~rY,O_f the Commission, U.S. Nucl1mr: iegu4ltory Commission, Waiihing~ori..I;>G;.29555, Attention:Docketing arid ~ice Branch. Copies of cominenis received by the Commissioti" ~ii:i~!i.~.~ruµineµ. 11t. the NRC*PublicDocunientRoom, 1717H* Street, NW.;'Washirigtoo; DC:20555; ~:: FOR FURTHER ~i:o..rw~TION*cp~~' Dennis K. Rathbµn odames G. Beckerly, Offict1 of Policy.Evaluation, U.S, Nuclear Regulatory C!;)mmiss_ian;'Washi11gton, D.C. 20555. Telephone [202) 634-3295. SUPPLEMENTARY INFORMATION: This sta.teme,nt gives the Comniission'.s policy for considerigg *advanceql'eactoril %ich are those reactor deslgml that are. significantly different from the light _. water reactors now under constructii>n or in operation.' Legislative Background '. The' Commission's policy with respect to regulation -of advan~'r~actors is. guided by th~ legislativ,!?:l>ackground.. The Energy Reorgimizafft?,rf Act of 1974, which established the N:udeat Regulatory.Commission; specifically*,.,,,. delegated to 'NRC licensing :and'retated regulatory *authority~ for.demonstration** nuclear reactors other than those *: *,.:* already in existence.:,;-, when operated as :part of-the power.generation facilities ofan electric utility* system; or when oper.liling*in,any.other manner for the purpose of. demo11strating.the *., - suitability for commercial application 'of. such*a reactor.,,}1 The.Energy Research and Development '... ,"'C Administration (now the:Department of: Energy) was cha.rged with", *.

• encouraging and condueting*~esearch and development, including -

demonstration of commerciat feasibility and practical applications -0f the :

• extraction, conversion, storage,* *.

transmission, and utilizatton*,phases* related to the.-development,and use of energy from.....,nuclear. ;

• sources.-:

UnderSection ID5:.of.the'Energy. Reorganization -Act, NRC must.proviae a "long-term plan for proje.cts for -the developmentof-newor itnproved,safety. systems* for nucleai' power-plants: "*The Commission is g~neraUy iimitedhy language in Congressional Cammittee reports to reseai'Gh on eafety systems to be incorporated into reactors of,current. design and -011.oonceptqal*-designs for

• both new systems and new reactors.-~.*:

NS~J~*~cluded from,des~ or to asstµ"e* adequ~te prot~ction of the longer time constants* to allow for more

• d9ing,_re~e_iµ-~h on complete new designs public health and safety and the*

diagnosis and management-prior to fro!Jl the-purpose;_of;e:stabli!Jhing or. environment, consistent with its reaching safety systems challenge. de_y,lopingJJ,.e4'J;pm¢~.l,'Cialpotential.. legislative requirements.

2. Simplified safety systems which

.. 'lli~~T!f~1ir~aa~i~i~ce :£~13~1~:::~1~:f::if ~~elf r:i::~~:::e::c~;:ee:i~w; :~:~:;e:e ' iii;tJiiitegulation oh.dvancecf reactors. will subjected to severe environmental In:Uitfearl'"1970'lNRc*reviewed.',. ' Commission. maintain the capability conditions), and the minimum number of ...,.,,,,_,,.,,,,..:,J,. -.-*-. _,,,... *. _ _. _. to respond to inilOvativitarid advanced components needed for maintaining safe s~veJ.f!l;applications for.high-,: -, *. _ *, *:

• desigris'that might be presented for tem)ief~ture, *gas-cooled reactors~.,..: ~-**,

Commission review. The,Commission shutdown conditions, thereby (!iTGRs)and a-t:Onceptual design-fora" intends to make known the factors it facilitating operator comprehension and . gas;cooled b_ree~er reactor, _and grante,;I. considers important for -advanced reliabll!. system function. Such an._operatingl_i'cense to Fort st.*. Vram*,* -* __.*1* d simplification can also reduce the* reactor concept.a m or er to minimize d h tha._only* *operal-4"_" HTGR. The* NRC *also'. uncertamties associate wit ... -e complexity' and"uncertainty in the* d d exp.ended sirlisfaritia:f ~ffort from 1975 fo regulatory P!"OC_~ss.. _ _ _, _ . eterministic engineering ju!igment an 1979.in.reviewing'Gerieral Atomii::'s* c On standardization of the current probabilistic risk analyses,. st~aard liighrt~mi:ie_raturei g_as-cooled. generation of nuclear'power reactors,.

3. Designs that (a) minimize the

.nu9ie~.reactor*steam supply system the Commission's 19a5'Policy and -,- potential for severe a.qcidents and their

• (G.t\\$$AR),_In addition, theNRC has Planning Gli.idanc;e state~:,-:*

consequences by providing suff!pient s.U.P.P.Qtlj,~t~.mog~_s! prqgripn of safety ., 0, -

• inherent safety, reliability, redundancy, i:ese~.<<m-.on,g'as~cp_oled reactors every.

The NRC.recognizes that there.are;: ' *, -

• diversity and independence in safe_ty*
• , sw advantages to the 4!lvelopmerit-Qd.use of ye~;!IJ!lc~'.tlie _agency's inception.,*_..
• standardized nuclear;power Pl/inf.and. __ * *
• systems: (b) provide reliable equipment

. : Tlf~~9i'~g its'tir~d~cessor; tht! balance of plant desians, Such "desi_gn** ,a.*_ can

• in thl;? rest,of tb.e plant; thereby reducing Atdmic Enif :Coirunissiori (AECf have benefit public health --:;~d safety l>Y: *.. -
• the *number:of:;c,l!~ll~nges to the safety

' ij!~bi\\i.ehjiJ,n~,ved;µ{j}iifr~vi.~~ a~d:, concentrating the resources of designers; systems: (c) p~oyide easily maintainable

• ijq~~J$fliqtiifiqe:tai)'.Ja'.st bt~e~~r.~ * ' _-

engineers and vendors.on particular* eqli.ipmentan_d:components: and:(dl: re:ii~l~ts, ~Rs).: Thiffel'llli~ 1" aria*'.,.... approaches, by stimulating*standardited. ' red11ce po,!311,tial radiation.e~pc,~~, to. SEFORreactors were reviewedand*' :

• programs ofconJ1truction practice and quality.-

l i-I lic~D$~~ DOits Faif Fl~ Text F.Jcili_;-; fu.' '. assur!!Jlce, by improving the trainiµg of a,: ' :,, p !',4n. In. pCI'ere 8a 0 snnede_,s_..'t"an', dardizatio\\n'* '."a*ntd*s,,hi. :p:

• n.vrm
• personnel.and by fostering mol'.8. effective* *.:...

lA4,,L..,-~as re:vi,~weclJµt,n~tlfoehseq, -. mallltensnce im~improved operaijqii The_. fabrication*to. mµrlmize the p_otential for ' ~~J.~Jp!-1J19J. H¢i:!p,ing~prc,ceediiig_was use of such* designs can alilo 11ermit more field construction errors without-'"-~*'. ::1.. : coridiicted.fol"tlie Clinch River Breeder effective and'efficient licensi,.;a and. ** ting diffi ulti

• f t
• t *

. - Ref~or'(CRijRJ;:TlifCRBRwas subject ' inspectioli-jirocesiies;* Theref6~; the" ' i:e~d tr~~;:rt, U:~tan:::.:/ry* o~. to~e s1:1IDer~gul~!ocyj:1rc;,cess Els.any. Commission strongly enriouragea'.industry to: maintenance.

~~[Th~gi~tae~t~~Pjrit~i -, -,.

: * ~:s~t:~~r~a~on in'fu~-~actor

5. DesignJeatures that can,be. proven

, ipctef~s;;~ ~iJ~ty:rese~!;hpr<?gi;@if~:~:.::. The Commissionis prepariiig'a policy-by citation ofexisting technology or. supP,Qrt o( ~~-~R' program* anii'llie-~*: ** statemenfl,ri,st(lhdardizatfoinvhich will. whic;:h can be,satisfactorily established. - CRBRlicemifug,_e~ort. )Nhen,the CRnR -;--: be *applicable,,fo'future-reacfors; by commitment to a suitable-technology

project waii.caiicelled;*NRC's research:",;

development program. program was revi~~d to ellmina te CRBRl '-:-. Propo~ed Poµcy_

• If specmc advanced reactor designs specific,worlc;: **::

The s;ommission's proposed policy is witb::bliara:i::teristics'such'as the>"'" -.-,.

• Fmally,.th_e_Co_mmission notes*tharthtf* to enco~age:the earliest poss1ble. ~..

foregojng wete"btoughtto the'NRC for precedent for'tne. broa~ policy approach ; interElotiq~ of applicants, yendor!i; other' comment and/ or-evaluation,' the-, ;;,:.~ tp*advanced*reactor: regulation, as,*,,_, go_vernment-agencies:and the NRC to Commission* could" develo1f preJiminarjv. prop,ose~1here,*.is, firmly est_ablished,in.,.,, provi!ie tlfe:most effective regula tipn for

• general design* and licensing :criteria 'for tJ,ie'.1979 N:on-proliferationAffi,l'll~tive!.:-', _;

advanced-reaptors, and to provid,e all their safety-related aspects. However,,* ~Yl!temi;AssessmentPrograniWA.SAP)n inte~e!J,t~d-parties; including the public, until such time as.detailed conceptual*. wherein;tbe NE:_C consjdered 'the :~afety2:L-. withJftjµlely,.independent assessment designs are submitted; the Conunissioil-

• ang_lic~~fl:lP.iµty o(ll,~ariety of:\\,:c,~~~1-i:,

of ~e;~afety:cJiaracte~stics of advanced

• believes that regulatory guidance must.

a<!r!IAC,~Q.. J;~~c~or-:ficm,i;:ep_ts,withhj.th_fii:t;: reacto'i;i:lesigns. Tlie NRC would* be sufficiently generalto avold placing

• CQJll_ext~~!: ~9.q~e!:Ql~f~;!J:.tio_n q~jecµve_s~if;;. Undertake; within its:stafutory unnecessary constraints on the'*.*.c Tli~:~~~<;~PJ!t<i?ii~igiired and :!"BP,Orled,. *.

respo_nsibiliti?~* to miajiti!~e"co~ple:aty

• development ohiew desigtj, conc"ilp,ts;~*-

c,n bY,cfhe.:~' 1q1tJicp,97!1.~tudyra,nged, *.*

• and add*sfabibty and p~ed1c~ab~Jj.ty m The number and nature ofregulatocy' from* prelimiq~,:*opceptutµ:de~igxµi:,to, the. li¢i!!rising)mdfegulatiqn'ohi:lvariced requirements will be based-0n-tlie "*.

Varll;\\tions, of existing:(L WR) power:*,... reactor~;*. ":* **.-. --_:

.,, :: -,~c, :,,: _.. -. ;,, ' *.

• extenno which* anindiviatial adv'ilnced plll!lfaj1~.sigp.!1*:~;~*,:<;-*"h'*:-,.,,:,:

The Gommission bel~eveii.tli'a:freacfor reactor design incorporates theiert~riil ~~~~~~lH~~~~li~~~; :*::~*:*::~:; ;: '~ ::!~~t:if!~a~~:~s~~=~~~~~ij~ll~wing ch~=;ri:i!c:v~~:~:~l;'~h~~~,~~~\\~:::* ;'.~ _.. ,:li.e;~l!~!~"ll!~~:tpoijcy with*~e~P,!!pt : desirable. Combinations* of i:lomi(or all advanced reactor development/Ute,-..

• to,,~~~~!~i~~cl!!~r.p.~~~r ~e.a.ct!>~}~;,;,;. of th_er:n ~ay help obtain early Ii_censing - * - Commission *particularly e_ncourages *

. -... *:' ;~., '\\" * ~)~_;,;,:::.:*: * -~:,, _ *.*.

• or standarizech\\esigj:l approval with*

design innovations whicli-mciease

• nf~s.~~i~tjii#i,tjp!e:d~fhiliis ti;~,~~~~,;_';// mini~WI!- regufo.tory burden-an~ should safety and reliability (sucll"'a~-.those **

NRC'.il'research_cari l>e described as_avoidlng ii * - be-~c,re:rel:ldily _understood 6y the-NRC,* described above)and which generally

• conf!ictC!finlereat"".(NRC]'should'never. beplai:ed ' the.utiliti~~-imd* the general public; depend on tec~ology which is. eitlier_

in position, lo,gell!rate, _and then,lia112 to defend,,, 1 D *,

• th t *
• '-f,
• b d d' b' baeicdeilignilatiisi(!!a*o:wn'.'ase#nissedhi'i,he..

,* es1gns a -reqwre-ew,' :.--: provenorcan e emonstrate

• ya Conference-Repo~io*theEnergyReorg~atioit'A"ct* supplemeii\\alteafety.:fe~~ures,to eniiure-. :, 'satisfactocy::techiiology,developlllenf' OfJJw.~:',;~;,;;'.:".::.ri::-~:~1'?,~i,:;~:':;;; *; '. ::+:,.,*\\*;::,:,, safety, imd/,oi-designs'that:provfde'~,* )C..

program;*:_* :. *-, _) t;*-,.1::e-~;;-:

• ,-,~-----**

Tlie.Coi:nmission's.ultimate goal is the approyal _of essentially CJ>mplete standard plant designs. However, advan~d re!ictor*deajgners im~ prosp~c;tive consu:uction pEl~mit applican,ts are ¢nco-uraged notJo wait until deta;Oed_ d~!iign~ are complete, but to subminechnic:-al'iiiformatioil on their prop'os:Mconcep_tual designs as far in advance of application as practicable, so that NRC staff may evaluate.. fundamental safety characteristics in a timely manner._ To eilhanc_e Commission participation and continuity ih the review of advanced reactors, a:nd advanced reactors group has been established in the Office of Nuclear Reactor gµlation. This group will be the focal nHor:NRc interaction with the

• partment of Energy, designers *

{domestk and foreign)and potential Aolicants and will prepare a plan for development ofregulatory criteria licensing.proposed advanced ctors. In addition, the group will. ovide gujdance on* an NRC-funded advanced-reactor research program to { - _ -.:.ensure that it,supports, and is consistent ~

with,,;the.Commissiori's advanced reactor:policy. The Advisory Committee on ReiictorSafeguards {ACRS} will play

. a significant,role in l'e17iewing l)ropOSed - advanced reactor design concepts and supporting activitiiis.. The.Commission wouid,also-Iike to be informed as early a![!*possible of new.* design-concepts under construction,by

• the_ ilnclear industry so thatrtbe,ataff can<

. review and comment on thajNndety and,,if;necessary, SUP,l)Ort~atory t research:on them. Whfle :tJ}e NRC itself \\ ldoeuiotdevelop Iiew designs, the -.. - mmission. inten9s to d.evelop the *, -l pabilityfor-timely, appropriate -.- _ 1 .J:isment and response to ~ovative, f' d adtved~~NRdeCsigns ~~t~ght be -* \\ presen

1or,

,rec111ew.*..,uor experience ha!I shown that *new-reactor._ I i_:~- designs-even variations of establi$ed Asign-may involve technical problems J.; ~t must be identified and solved in order to assure adequate protection of the public health and safety. The earlier such design problems are identified, the earliei:-.satisfactory resolution can be achieved. When informing the NRC of new concepts under consideration, prospective applicants should understand that they are responsible for all research nece~ary to support any specific lice~ application. NRC researtji is conducted only to provide the technical bases for rulemaking and r~gula.tory decisions; to support hcensmg and inspection activities; to assess ~ feasibility an.cl.effectiveness of S\\lfety j~provements; and to increase our un!le~~qi,ng 9f pheno~ena for,.:

• - demonstration,of-.an aavanced,reactor,:-;,

which 1;1ruij.y~c.al m~lh9~,~~--~~!Ntin -, concept ~rior "! ~ Jicensiilg,o(a :.,/' regulatory.-:~~itill:5. :.. : -,--:,-..., - commel'Clal_~ty?,. -: ~ ** * ~ _:,.;:,,_,.,.,.. Questions....:*::.-~- ':; ::"'_';:.::t'. :~: *_ .. Diited-at-Washlhgton; Dl:.;' this flstd~y--of' -March _1985,

• A number.of basic issues: were -* *.. -. :::

.F th N 1 R gulat c

• io identified in-~velopnie~tqfthis policy.'-'

or 8 : UC e.ar e. ory. OIDDUBB n.. ?.E""~J=~00:. ~~i~~Ei: any other aspects of the.policy -_, _.,;- -*: 81WNG *co~Uft0-Cl1..,, -';"_t:':s_::,,yr-::*~:;, statement: ,;:0,:.1;,,:*,:,,:,.*. :

1. Should NRCs l'egulatory approach..

be revised to r~ce dependence* on;::*. prescriptive regulatiomi. and._ instead.._ eo-~~ictiuoniiir*ct~,_-*.: establish-less prescriptive~esign.. A*men-dm* 'en' :a.... ., *.,_~,----- objectives, su_ch,as_pedorma~ce _ *.. 1ut standards? If.so; in w,liat alip~ct,s',of < *.*,,..

• AG~~;-;~clear'Re~atory_** -~.... ::., '

nuclear power,pla~.ciesign [f<>r.*. :. -. '<': C example, reactoi'j:ore pQwer,d~ey... _.~_:r-oll~ditile. -* reactor.core-heat removal, contairimeIJ.t.. ..,.""'.,P.. and siting)~ght_the pe~n~f~: '.:'\\ sui.i.t~r.TheNucleai-Regulat~ry,, '.,, standards approachbe:applie*dmost-:.. * *_ nd - effectively1 How could:unpJementation,.' Comiqisirion~{l'ffl9proposes t<>.:~e _.-.. - of these performance_ s~ar~!J-.e~'<,:"' -_ its. te~tiorurtha:t es~blish Ui!:S'., p'ro~<;l~ll fqr* sul:,initting verified?: cori'.es_pondence, ~.ep\\)rts. applica~o~.or-

2. Should-the-regulations fOJ',advanced ofher'.vm.'_*_ tt_ en.comm_

.. unioatioris p' ert_ -_ nmmn* reactors require more mher.ent safety- ~- ..... ~ margin m:th~ir -design?U so,~should the to fhe:,!:JO~~.!ltic.l!!Jensing of production:;.: emphasis be on providing features *thaf and utilizatimil!icilities.e The prbposed- _ permit more time.for operator re~onse. amen~elits ~mcate*the correct mailing to off-nornuircionditiomi, or should the adclrti!ls:for deY,vecy*ofthe emphasis.b~.on providing sys~s ~t - commiuucationa.and specify_ the_numoer. lll,'e c~able*qfJimcti~nizig ~d~- __,.. . of copi§!f require&, t~rfacilita6,* ecuqnby, conditions,that-exoeed the cdesign,basisY : the]-JRC; The,proposed' aµien~ts~Jt*, *

3. ShouldJicerisiogregulationdor,..

• adopte~;Jire..e~=-d-m,i-~~~l_ve.a :*_: ~'~-

advanced reactors mandate,~implified :* ~~~=~~ci~*a!;~f i;V~itl yi~:.: d~s whicltteqtlire thefew.~.st - - re~"_..,.i __.:.*-..;. -.*th*e.. 1J~1.. __...; _*;*u *.al o.f app'iliciitio_*

• ns*_*

ope~atm actions, and,~ ;min.4nup1 ~. ~~~....,..,..._ number ofoomponents ~e~ded-for,- _ :. and reports: lri'additirin,io,clarifyµig,tlith. achieving and maintaining !l!!f~ _ _ proi:eihires; these :amendments wilL~::';~~,, shutdown conditions, 'thereby * * : :c" : *:,: : . resulfin.a reductio1j'in reproductim.iruicl' facilitatigg ~perl!tor;JilPJ'.~t:!Il8i.Qp and. postage,colits for the affecte<<J. :\\i,c.erisEitl~:~:

• reliable sys~mJw1(:ti_on fo_r off-~al,

DATE:-.Comment perioch~pires*.May:2.& *.. conditions? '_.,, :> :,1,,,. 1965,:Comments,received afteithisidate\\=

4. Should the NRC.-devel~p ge~¢ral.- -'.:

will'.be consideredifitis*practical:todo:' des~ c.rite~a-for :ad~ced r~actors by_ ; so~*bulusurance of consider.a_tion._ ; :. * :, modifying th~ existing regajatio~,_, 0 :

• cannot-be given*exceptfor ihoBe :~, ": * ":/r
• which were dev.eloped for the cumµit comments*received-on or before' this ** -'s generation of )ight water r~ctors, -or by date.

dev.eloping 8 ne,w set of general design. -* ADDRESSES: Interested persons are criteria applicable to specific concepts invited to-sttbmit*written comments and which are bro~t be!Ql'e the -. suggestions to the Secretary of the --* *r **

• Commission?_.,*.
• Commission,ltS.-Nuclear Regulatory

5. Should the,NRC favor advanced CommisiJion;Washingtoil, DC'20555, reactor designs that_ concentrate the Attention: Docketing and Services primary safety functions in very few Branch.

large systems {rather than.ip. multiple subsystems), thereby minimizing-the FOR FURTHER INFORMATION CONTACT: need for complex benefit and cost Steve Scott. DocumentManageme.,nt -*,

• b

~ fe Branch..Division of Technical '" alencing in the engineering 1.u sa * - y..:.'~ormalion and Docume'. nt _Control, *. - - reactors? llll'

6. What degree of proof :w.ould be_,

Office of Administration; Nuclear sufficlentfor the NRC to fmd that a new Regulatory Commission, Was~ design is based on technolo_gy whidi is DC 20555, Telephone: (301) 492-'-8585, eithel' proven or can be demonstrated by SUPPUIIENTARY BIFORIIATION: &cause a satisfactory technology !iev~lopment of recent revisions to the NRC's *- pro~amr For.exam.pie, is it n~~BSall' or reguireinents for:~)ubmittal of -_..:... advis~ to require ~jvo~~ inforin_ation by' applicants.and licerureea,* _..}}